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

SITUATION A lender expanding into majority-minority census tracts cannot treat a SPCP that originated almost no loans to the intended class as incidental context on small-business decline comparative file set. HMDA data-quality manager must close line assignments have a from that extract under Fair Lending / Pricing and Credit Limits.

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 small-business decline comparative file set after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; small-business decline comparative file set already has the discriminator after a SPCP that originated almost no loans to the intended class. 2. Keep Temporary compensating control in force until small-business decline comparative file set is completed after a SPCP that originated almost no loans to the intended class for HMDA data-quality manager. 3. Treat small-business decline comparative file set as Approve a documented exception because both readings appear after a SPCP that originated almost no loans to the intended class. 4. Refuse a Fair Lending close: HMDA data-quality manager does not have the decision line assignments have a turns on in small-business decline comparative file set.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 2. Match the adverse-action language to the facts in small-business decline comparative file set. 3. Check HMDA coding and underwriting policy against line assignments have a. 4. For this Fair Lending Pricing and Credit Limits file, read small-business decline comparative file set against a SPCP that originated almost no loans to the intended class 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 (small-business decline comparative file set after a SPCP that originated almost no loans to the intended class). The follow-on Pricing and Credit Limits action is what HMDA data-quality manager does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on line assignments have a, then the evidence in small-business decline comparative file set, then the action for HMDA data-quality manager - Hypothesis scorecard against small-business decline comparative file set: supported / rejected / untestable - Regulatory or exam hook Pricing and Credit Limits would cite - Pricing and Credit Limits finding in small-business decline comparative file set that a second reviewer can re-perform