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

Situation

In a bank with thin HMDA LAR quality, geographic application and origination heat map is the evidence after a branch that stopped taking applications in one ZIP. Exam-response coordinator has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data close using geographic application and origination heat map.

Decision

Exam-response coordinator 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 geographic application and origination heat map after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• The population in geographic application and origination heat map is the one a branch that stopped taking applications in one ZIP named, so Remove access or reverse the item follows for this Redlining and HMDA Data file.
• The population in geographic application and origination heat map is adjacent only to a branch that stopped taking applications in one ZIP; Temporary compensating control is the honest Fair Lending call.
• A bank with thin HMDA LAR quality already contained a branch that stopped taking applications in one ZIP before geographic application and origination heat map arrived; no new Redlining and HMDA Data path.
• Provenance on geographic application and origination heat map after a branch that stopped taking applications in one ZIP is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Flag any disparate-impact table exam-response coordinator cannot explain from geographic application and origination heat map.
• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• Match the adverse-action language to the facts in geographic application and origination heat map.
• For this Fair Lending Redlining and HMDA Data file, read geographic application and origination heat map against a branch that stopped taking applications in one ZIP 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 / Redlining and HMDA Data packet (geographic application and origination heat map after a branch that stopped taking applications in one ZIP). If geographic application and origination heat map cannot force a Fair Lending label under Redlining and HMDA Data, stop. If geographic application and origination heat map after a branch that stopped taking applications in one ZIP cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Redlining and HMDA Data close, exam-response coordinator must do not infer a control or scheme beyond the transaction and entitlement evidence.