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

SITUATION After a community complaint about appraisal gaps, underwriting exception log by branch is what community-development lender can touch in a bank with thin HMDA LAR quality. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Pricing and Credit Limits file.

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 community complaint about appraisal gaps.

HYPOTHESES TO TEST 1. A community complaint about appraisal gaps is noise around an already-controlled Pricing and Credit Limits process in a bank with thin HMDA LAR quality, given underwriting exception log by branch. 2. A community complaint about appraisal gaps is the event in underwriting exception log by branch that forces Remove access or reverse the item for community-development lender under Fair Lending. 3. Underwriting exception log by branch shows a one-file miss after a community complaint about appraisal gaps, not a Pricing and Credit Limits program failure. 4. Underwriting exception log by branch cannot decide line assignments have a yet after a community complaint about appraisal gaps; hold is the only Fair Lending close a bank with thin HMDA LAR quality can defend.

ANALYSIS REQUIRED 1. Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps. 2. Flag any disparate-impact table community-development lender cannot explain from underwriting exception log by branch. 3. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 4. For this Fair Lending Pricing and Credit Limits file, read underwriting exception log by branch against a community complaint about appraisal gaps 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 community complaint about appraisal gaps). Lead with the Fair Lending option underwriting exception log by branch can support after a community complaint about appraisal gaps, 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 - Missing page in underwriting exception log by branch after a community complaint about appraisal gaps, if any - Regulatory or exam hook Pricing and Credit Limits would cite