Assess whether notices match the actual decisioning reasons (ef4f0f)

SITUATION In a bank with thin HMDA LAR quality, small-business decline comparative file set is the evidence after a community complaint about appraisal gaps. Fair-lending officer has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs close using small-business decline comparative file set.

DECISION Fair-lending officer 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 community complaint about appraisal gaps.

HYPOTHESES TO TEST 1. The population in small-business decline comparative file set is the one a community complaint about appraisal gaps named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file. 2. The population in small-business decline comparative file set is adjacent only to a community complaint about appraisal gaps; Temporary compensating control is the honest Fair Lending call. 3. A bank with thin HMDA LAR quality already contained a community complaint about appraisal gaps before small-business decline comparative file set arrived; no new CRA and Special-Purpose Programs path. 4. Provenance on small-business decline comparative file set after a community complaint about appraisal gaps is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against notices match the actual. 2. Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps. 3. Flag any disparate-impact table fair-lending officer cannot explain from small-business decline comparative file set. 4. For this Fair Lending CRA and Special-Purpose Programs file, read small-business decline comparative file set against a community complaint about appraisal gaps and write the one fact that would move notices match the actual for fair-lending officer.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (small-business decline comparative file set after a community complaint about appraisal gaps). If small-business decline comparative file set cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If small-business decline comparative file set after a community complaint about appraisal gaps cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, fair-lending officer must do not infer a control or scheme beyond the transaction and entitlement evidence.