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

SITUATION A bank with thin HMDA LAR quality cannot treat an exception rate twice as high for one group after credit controls as incidental context on mortgage pricing residual by prohibited-basis group. Community-development lender must close line assignments have a from that extract under Fair Lending / Pricing and Credit Limits.

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 mortgage pricing residual by prohibited-basis group after an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. Community-development lender can defend Remove access or reverse the item from mortgage pricing residual by prohibited-basis group after an exception rate twice as high for one group after credit controls in a Fair Lending challenge. 2. Community-development lender cannot defend Remove access or reverse the item from mortgage pricing residual by prohibited-basis group; Temporary compensating control is what the extract actually supports after an exception rate twice as high for one group after credit controls. 3. An exception rate twice as high for one group after credit controls never reached the population in mortgage pricing residual by prohibited-basis group — reopen intake, do not close line assignments have a. 4. Two facts in mortgage pricing residual by prohibited-basis group after an exception rate twice as high for one group after credit controls conflict for community-development lender; hold this Pricing and Credit Limits file.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 2. Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group. 3. Check HMDA coding and underwriting policy against line assignments have a. 4. For this Fair Lending Pricing and Credit Limits file, read mortgage pricing residual by prohibited-basis group against an exception rate twice as high for one group after credit controls 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 (mortgage pricing residual by prohibited-basis group after an exception rate twice as high for one group after credit controls). The follow-on Pricing and Credit Limits action is what community-development lender does next: implement the option, assign an owner, and log the missing fact.