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

Situation

In an institution preparing for a redlining exam, credit-card limit assignment disparity table is the evidence after a marketing mailer that skipped majority-minority tracts. CRA strategist has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data close using credit-card limit assignment disparity table.

Decision

CRA strategist 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 credit-card limit assignment disparity table after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• The population in credit-card limit assignment disparity table is the one a marketing mailer that skipped majority-minority tracts named, so Remove access or reverse the item follows for this Redlining and HMDA Data file.
• The population in credit-card limit assignment disparity table is adjacent only to a marketing mailer that skipped majority-minority tracts; Temporary compensating control is the honest Fair Lending call.
• An institution preparing for a redlining exam already contained a marketing mailer that skipped majority-minority tracts before credit-card limit assignment disparity table arrived; no new Redlining and HMDA Data path.
• Provenance on credit-card limit assignment disparity table after a marketing mailer that skipped majority-minority tracts is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• Match the adverse-action language to the facts in credit-card limit assignment disparity table.
• Check HMDA coding and underwriting policy against line assignments have a.
• For this Fair Lending Redlining and HMDA Data file, read credit-card limit assignment disparity table against a marketing mailer that skipped majority-minority tracts 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 / Redlining and HMDA Data packet (credit-card limit assignment disparity table after a marketing mailer that skipped majority-minority tracts). The follow-on Redlining and HMDA Data action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.