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

SITUATION The working file is underwriting exception log by branch after a board asking if the bank should settle a matched-pair study. CRA strategist in a bank with thin HMDA LAR quality has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices file.

DECISION CRA strategist 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 board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; underwriting exception log by branch 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 underwriting exception log by branch is completed after a board asking if the bank should settle a matched-pair study for CRA strategist. 3. Treat underwriting exception log by branch 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: CRA strategist does not have the decision line assignments have a turns on in underwriting exception log by branch.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against line assignments have a. 2. Compare underwriting exception log by branch 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 CRA strategist cannot explain from underwriting exception log by branch. 4. For this Fair Lending Examination and Notices file, read underwriting exception log by branch 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 CRA strategist.

RECOMMENDATION CRA strategist should take Temporary compensating control on line assignments have a unless underwriting exception log by branch after a board asking if the bank should settle a matched-pair study already proves Remove access or reverse the item for this Examination and Notices packet in a bank with thin HMDA LAR quality. Keep Approve a documented exception live only while underwriting exception log by branch is missing the decision line assignments have a turns on. The working test on underwriting exception log by branch is whether Check HMDA coding and underwriting policy against line assignments have a..

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 CRA strategist - Hypothesis scorecard against underwriting exception log by branch: supported / rejected / untestable - Regulatory or exam hook Examination and Notices would cite - Examination and Notices finding in underwriting exception log by branch that a second reviewer can re-perform