Assess whether line assignments have a disparate impact the bank will defend

SITUATION CRA and Special-Purpose Programs work in a mortgage company after a pricing-regression spike now turns on line assignments have a because a vendor score change with no disparate-impact test put manufactured-housing dealer overlay notes in play. CRA strategist should say what manufactured-housing dealer overlay notes proves.

DECISION CRA strategist in a mortgage company after a pricing-regression spike must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using manufactured-housing dealer overlay notes after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. The population in manufactured-housing dealer overlay notes is the one a vendor score change with no disparate-impact test named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file. 2. The population in manufactured-housing dealer overlay notes is adjacent only to a vendor score change with no disparate-impact test; Temporary compensating control is the honest Fair Lending call. 3. A mortgage company after a pricing-regression spike already contained a vendor score change with no disparate-impact test before manufactured-housing dealer overlay notes arrived; no new CRA and Special-Purpose Programs path. 4. Provenance on manufactured-housing dealer overlay notes after a vendor score change with no disparate-impact test 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 line assignments have a. 2. Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test. 3. Flag any disparate-impact table CRA strategist cannot explain from manufactured-housing dealer overlay notes. 4. For this Fair Lending CRA and Special-Purpose Programs file, read manufactured-housing dealer overlay notes against a vendor score change with no disparate-impact test and write the one fact that would move line assignments have a for CRA strategist.

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 (manufactured-housing dealer overlay notes after a vendor score change with no disparate-impact test). The follow-on CRA and Special-Purpose Programs action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on line assignments have a, then the evidence in manufactured-housing dealer overlay notes, then the action for CRA strategist - Hypothesis scorecard against manufactured-housing dealer overlay notes: supported / rejected / untestable - Named option among Remove access or reverse the item, Temporary compensating control, Approve a documented exception and the fact that kills the others - Owner and next date for CRA strategist in a mortgage company after a pricing-regression spike