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

SITUATION Community-development lender in an institution preparing for a redlining exam has one working extract — geographic application and origination heat map — after a board asking if the bank should settle a matched-pair study. If geographic application and origination heat map cannot support line assignments have a, the only defensible Fair Lending output is hold.

DECISION Community-development lender in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using geographic application and origination heat map after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; geographic application and origination heat map already has the discriminator after a board asking if the bank should settle a matched-pair study. 2. Keep Temporary compensating control in force until geographic application and origination heat map is completed after a board asking if the bank should settle a matched-pair study for community-development lender. 3. Treat geographic application and origination heat map as Approve a documented exception because both readings appear after a board asking if the bank should settle a matched-pair study. 4. Refuse a Fair Lending close: community-development lender does not have the decision line assignments have a turns on in geographic application and origination heat map.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against line assignments have a. 2. Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study. 3. Flag any disparate-impact table community-development lender cannot explain from geographic application and origination heat map. 4. For this Fair Lending CRA and Special-Purpose Programs file, read geographic application and origination heat map against a board asking if the bank should settle a matched-pair study 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 / CRA and Special-Purpose Programs packet (geographic application and origination heat map after a board asking if the bank should settle a matched-pair study). The follow-on CRA and Special-Purpose Programs action is what community-development lender does next: implement the option, assign an owner, and log the missing fact.