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

SITUATION Geographic application and origination heat map arrived with an exception rate twice as high for one group after credit controls for HMDA data-quality manager. That is a Fair Lending Pricing and Credit Limits decision on line assignments have a in a lender expanding into majority-minority census tracts.

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 geographic application and origination heat map 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 a lender expanding into majority-minority census tracts, given geographic application and origination heat map. 2. An exception rate twice as high for one group after credit controls is the event in geographic application and origination heat map that forces Remove access or reverse the item for HMDA data-quality manager under Fair Lending. 3. Geographic application and origination heat map 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. Geographic application and origination heat map 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 a lender expanding into majority-minority census tracts can defend.

ANALYSIS REQUIRED 1. Flag any disparate-impact table HMDA data-quality manager cannot explain from geographic application and origination heat map. 2. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 3. Match the adverse-action language to the facts in geographic application and origination heat map. 4. For this Fair Lending Pricing and Credit Limits file, read geographic application and origination heat map 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 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 (geographic application and origination heat map after an exception rate twice as high for one group after credit controls). If geographic application and origination heat map cannot force a Fair Lending label under Pricing and Credit Limits, stop. If geographic application and origination heat map after an exception rate twice as high for one group after credit controls cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Pricing and Credit Limits close, HMDA data-quality manager must do not infer a control or scheme beyond the transaction and entitlement evidence.