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

SITUATION Examination and Notices work in an institution preparing for a redlining exam now turns on line assignments have a because a notice that cites 'other' as the principal reason 40% of the time put small-business decline comparative file set in play. Examination and Notices work in an institution preparing for a redlining exam now turns on line assignments have a because a notice that cites 'other' as the principal reason 40% of the time put small-business decline comparative file set in play; fair-lending officer should say what small-business decline comparative file set proves for Fair Lending.

DECISION Fair-lending officer 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 small-business decline comparative file set 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 Examination and Notices process in an institution preparing for a redlining exam, given small-business decline comparative file set. 2. A notice that cites 'other' as the principal reason 40% of the time is the event in small-business decline comparative file set that forces Remove access or reverse the item for fair-lending officer under Fair Lending. 3. Small-business decline comparative file set shows a one-file miss after a notice that cites 'other' as the principal reason 40% of the time, not a Examination and Notices program failure. 4. Small-business decline comparative file set 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 an institution preparing for a redlining exam can defend.

ANALYSIS REQUIRED 1. Flag any disparate-impact table fair-lending officer cannot explain from small-business decline comparative file set. 2. Test a documented exception versus a pattern an institution preparing for a redlining exam must defend. 3. Match the adverse-action language to the facts in small-business decline comparative file set. 4. For this Fair Lending Examination and Notices file, read small-business decline comparative file set 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 fair-lending officer.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (small-business decline comparative file set after a notice that cites 'other' as the principal reason 40% of the time). If small-business decline comparative file set cannot force a Fair Lending label under Examination and Notices, stop. If small-business decline comparative file set after a notice that cites 'other' as the principal reason 40% of the time cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Examination and Notices close, fair-lending officer must do not infer a control or scheme beyond the transaction and entitlement evidence.