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

SITUATION Pricing and Credit Limits work in an institution preparing for a redlining exam now turns on line assignments have a because an exception rate twice as high for one group after credit controls put CRA assessment-area versus lending footprint in play. Exam-response coordinator should say what CRA assessment-area versus lending footprint proves.

DECISION Exam-response coordinator 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 CRA assessment-area versus lending footprint after an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. An exception rate twice as high for one group after credit controls is noise around an already-controlled Pricing and Credit Limits process in an institution preparing for a redlining exam, given CRA assessment-area versus lending footprint. 2. An exception rate twice as high for one group after credit controls is the event in CRA assessment-area versus lending footprint that forces Remove access or reverse the item for exam-response coordinator under Fair Lending. 3. CRA assessment-area versus lending footprint shows a one-file miss after an exception rate twice as high for one group after credit controls, not a Pricing and Credit Limits program failure. 4. CRA assessment-area versus lending footprint cannot decide line assignments have a yet after an exception rate twice as high for one group after credit controls; hold is the only Fair Lending close an institution preparing for a redlining exam can defend.

ANALYSIS REQUIRED 1. Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls. 2. Flag any disparate-impact table exam-response coordinator cannot explain from CRA assessment-area versus lending footprint. 3. Test a documented exception versus a pattern an institution preparing for a redlining exam must defend. 4. For this Fair Lending Pricing and Credit Limits file, read CRA assessment-area versus lending footprint 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 exam-response coordinator.

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 (CRA assessment-area versus lending footprint after an exception rate twice as high for one group after credit controls). If CRA assessment-area versus lending footprint cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent missing evidence an institution preparing for a redlining exam does not have.