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

SITUATION After an underwriter chat that used coded language, HMDA LAR validity and quality edits is what CRA strategist can touch in an institution preparing for a redlining exam. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Redlining and HMDA Data file.

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 HMDA LAR validity and quality edits after an underwriter chat that used coded language.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; HMDA LAR validity and quality edits already has the discriminator after an underwriter chat that used coded language. 2. Keep Temporary compensating control in force until HMDA LAR validity and quality edits is completed after an underwriter chat that used coded language for CRA strategist. 3. Treat HMDA LAR validity and quality edits as Approve a documented exception because both readings appear after an underwriter chat that used coded language. 4. Refuse a Fair Lending close: CRA strategist does not have the decision line assignments have a turns on in HMDA LAR validity and quality edits.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against line assignments have a. 2. Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language. 3. Flag any disparate-impact table CRA strategist cannot explain from HMDA LAR validity and quality edits. 4. For this Fair Lending Redlining and HMDA Data file, read HMDA LAR validity and quality edits against an underwriter chat that used coded language 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 (HMDA LAR validity and quality edits after an underwriter chat that used coded language). 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.

COMMAND RETURNS - Bottom-line Fair Lending option on line assignments have a, then the evidence in HMDA LAR validity and quality edits, then the action for CRA strategist - Hypothesis scorecard against HMDA LAR validity and quality edits: supported / rejected / untestable - Owner and next date for CRA strategist in an institution preparing for a redlining exam - What changes line assignments have a if an underwriter chat that used coded language is later withdrawn