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

SITUATION After a HMDA resubmission that still fails quality edits, underwriting exception log by branch is the working evidence for community-development lender in a bank with thin HMDA LAR quality. Decide whether line assignments have a disparate impact the bank will defend using only what underwriting exception log by branch actually supports.

DECISION Community-development lender 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 underwriting exception log by branch after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; underwriting exception log by branch already has the discriminator after a HMDA resubmission that still fails quality edits. 2. Keep Temporary compensating control in force until underwriting exception log by branch is completed after a HMDA resubmission that still fails quality edits for community-development lender. 3. Treat underwriting exception log by branch as Approve a documented exception because both readings appear after a HMDA resubmission that still fails quality edits. 4. Refuse a Fair Lending close: community-development lender does not have the decision line assignments have a turns on in underwriting exception log by branch.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in underwriting exception log by branch. 2. Check HMDA coding and underwriting policy against line assignments have a. 3. Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits. 4. For this Fair Lending Pricing and Credit Limits file, read underwriting exception log by branch against a HMDA resubmission that still fails quality edits and write the one fact that would move line assignments have a for community-development lender.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (underwriting exception log by branch after a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option underwriting exception log by branch can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for community-development lender in a bank with thin HMDA LAR quality.

COMMAND RETURNS - Bottom-line Fair Lending option on line assignments have a, then the evidence in underwriting exception log by branch, then the action for community-development lender - Hypothesis scorecard against underwriting exception log by branch: supported / rejected / untestable - What changes line assignments have a if a HMDA resubmission that still fails quality edits is later withdrawn - Named option among Remove access or reverse the item, Temporary compensating control, Approve a documented exception and the fact that kills the others