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

Situation

A credit-card issuer changing line-assignment logic cannot treat a DOJ or CFPB monitor request for pricing files as color commentary on CRA assessment-area versus lending footprint. HMDA data-quality manager must close line assignments have a from that extract under Fair Lending / Redlining and HMDA Data.

Decision

HMDA data-quality manager in a credit-card issuer changing line-assignment logic 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 DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• Authorize Remove access or reverse the item now; CRA assessment-area versus lending footprint already has the discriminator after a DOJ or CFPB monitor request for pricing files.
• Keep Temporary compensating control in force until CRA assessment-area versus lending footprint is completed after a DOJ or CFPB monitor request for pricing files for HMDA data-quality manager.
• Treat CRA assessment-area versus lending footprint as Approve a documented exception because both readings appear after a DOJ or CFPB monitor request for pricing files.
• Refuse a Fair Lending close: HMDA data-quality manager does not have the page line assignments have a turns on in CRA assessment-area versus lending footprint.

Analysis required

• Flag any disparate-impact table HMDA data-quality manager cannot explain from CRA assessment-area versus lending footprint.
• Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend.
• Match the adverse-action language to the facts in CRA assessment-area versus lending footprint.
• For this Fair Lending Redlining and HMDA Data file, read CRA assessment-area versus lending footprint against a DOJ or CFPB monitor request for pricing files 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 / Redlining and HMDA Data packet (CRA assessment-area versus lending footprint after a DOJ or CFPB monitor request for pricing files). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after a DOJ or CFPB monitor request for pricing files, then the two facts that force it, then the Monday action for HMDA data-quality manager in a credit-card issuer changing line-assignment logic.