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

SITUATION A HMDA resubmission that still fails quality edits raised whether line assignments have a disparate impact the bank will defend for HMDA data-quality manager at a lender expanding into majority-minority census tracts. CRA assessment-area versus lending footprint is incomplete relative to that question, so Hold remains live until the file is complete.

DECISION HMDA data-quality manager in a lender expanding into majority-minority census tracts must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using CRA assessment-area versus lending footprint after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; CRA assessment-area versus lending footprint already has the discriminator after a HMDA resubmission that still fails quality edits. 2. Keep Temporary compensating control in force until CRA assessment-area versus lending footprint is completed after a HMDA resubmission that still fails quality edits for HMDA data-quality manager. 3. Treat CRA assessment-area versus lending footprint as Approve a documented exception because both readings appear after a HMDA resubmission that still fails quality edits. 4. Refuse a Fair Lending close: HMDA data-quality manager does not have the decision line assignments have a turns on in CRA assessment-area versus lending footprint.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against line assignments have a. 2. Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits. 3. Flag any disparate-impact table HMDA data-quality manager cannot explain from CRA assessment-area versus lending footprint. 4. For this Fair Lending Pricing and Credit Limits file, read CRA assessment-area versus lending footprint against a HMDA resubmission that still fails quality edits and write the one fact that would move line assignments have a for HMDA data-quality manager.

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 a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for HMDA data-quality manager in a lender expanding into majority-minority census tracts.