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

SITUATION CRA and Special-Purpose Programs work in a credit union rolling out a special-purpose credit program now turns on line assignments have a because a community complaint about appraisal gaps put small-business decline comparative file set in play. HMDA data-quality manager should say what small-business decline comparative file set proves.

DECISION HMDA data-quality manager in a credit union rolling out a special-purpose credit program 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 community complaint about appraisal gaps.

HYPOTHESES TO TEST 1. HMDA data-quality manager can defend Remove access or reverse the item from small-business decline comparative file set after a community complaint about appraisal gaps in a Fair Lending challenge. 2. HMDA data-quality manager cannot defend Remove access or reverse the item from small-business decline comparative file set; Temporary compensating control is what the extract actually supports after a community complaint about appraisal gaps. 3. A community complaint about appraisal gaps never reached the population in small-business decline comparative file set — reopen intake, do not close line assignments have a. 4. Two facts in small-business decline comparative file set after a community complaint about appraisal gaps conflict for HMDA data-quality manager; hold this CRA and Special-Purpose Programs file.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program 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 CRA and Special-Purpose Programs file, read small-business decline comparative file set against a community complaint about appraisal gaps 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 / CRA and Special-Purpose Programs packet (small-business decline comparative file set after a community complaint about appraisal gaps). The follow-on CRA and Special-Purpose Programs 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 - Named option among Remove access or reverse the item, Temporary compensating control, Approve a documented exception and the fact that kills the others - Owner and next date for HMDA data-quality manager in a credit union rolling out a special-purpose credit program