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

SITUATION Exam-response coordinator is responsible for line assignments have a in a manufactured-housing lender, using dealer-originated files with manufactured-housing dealer overlay notes as the only working extract. A notice that cites 'other' as the principal reason 40% of the time is what reset the timeline for this Fair Lending CRA and Special-Purpose Programs file.

DECISION Exam-response coordinator in a manufactured-housing lender with dealer-originated files must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using manufactured-housing dealer overlay notes after a notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. A notice that cites 'other' as the principal reason 40% of the time is noise around an already-controlled CRA and Special-Purpose Programs process in a manufactured-housing lender with dealer-originated files, given manufactured-housing dealer overlay notes. 2. A notice that cites 'other' as the principal reason 40% of the time is the event in manufactured-housing dealer overlay notes that forces Remove access or reverse the item for exam-response coordinator under Fair Lending. 3. Manufactured-housing dealer overlay notes shows a one-file miss after a notice that cites 'other' as the principal reason 40% of the time, not a CRA and Special-Purpose Programs program failure. 4. Manufactured-housing dealer overlay notes cannot decide line assignments have a yet after a notice that cites 'other' as the principal reason 40% of the time; hold is the only Fair Lending close a manufactured-housing lender with dealer-originated files can defend.

ANALYSIS REQUIRED 1. Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time. 2. Flag any disparate-impact table exam-response coordinator cannot explain from manufactured-housing dealer overlay notes. 3. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 4. For this Fair Lending CRA and Special-Purpose Programs file, read manufactured-housing dealer overlay notes against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move line assignments have a for exam-response coordinator.

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 (manufactured-housing dealer overlay notes after a notice that cites 'other' as the principal reason 40% of the time). The follow-on CRA and Special-Purpose Programs action is what exam-response coordinator does next: implement the option, assign an owner, and log the missing fact.