Assess whether notices match the actual decisioning reasons (72ffbe)

SITUATION A bank with thin HMDA LAR quality cannot treat a DOJ or CFPB monitor request for pricing files as incidental context on small-business decline comparative file set. CRA strategist must close notices match the actual from that extract under Fair Lending / Examination and Notices.

DECISION CRA strategist in a bank with thin HMDA LAR quality must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using small-business decline comparative file set after a DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. Small-business decline comparative file set reads as Remove access or reverse the item once a DOJ or CFPB monitor request for pricing files is lined up to the same Fair Lending population. 2. Small-business decline comparative file set is closer to Temporary compensating control after a DOJ or CFPB monitor request for pricing files; Remove access or reverse the item would over-claim this Examination and Notices extract. 3. Approve a documented exception is still live in small-business decline comparative file set for CRA strategist in a bank with thin HMDA LAR quality. 4. Small-business decline comparative file set is missing the fact CRA strategist needs after a DOJ or CFPB monitor request for pricing files; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files. 2. Flag any disparate-impact table CRA strategist cannot explain from small-business decline comparative file set. 3. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 4. For this Fair Lending Examination and Notices file, read small-business decline comparative file set against a DOJ or CFPB monitor request for pricing files and write the one fact that would move notices match the actual for CRA strategist.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (small-business decline comparative file set after a DOJ or CFPB monitor request for pricing files). Lead with the Fair Lending option small-business decline comparative file set can support after a DOJ or CFPB monitor request for pricing files, then the two facts that force it, then the Monday action for CRA strategist in a bank with thin HMDA LAR quality.

COMMAND RETURNS - Bottom-line Fair Lending option on notices match the actual, then the evidence in small-business decline comparative file set, then the action for CRA strategist - Hypothesis scorecard against small-business decline comparative file set: supported / rejected / untestable - Examination and Notices finding in small-business decline comparative file set that a second reviewer can re-perform - Missing page in small-business decline comparative file set after a DOJ or CFPB monitor request for pricing files, if any