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

SITUATION The working file is manufactured-housing dealer overlay notes after a marketing mailer that skipped majority-minority tracts. Model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data file.

DECISION Model-risk partner for credit scoring 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 manufactured-housing dealer overlay notes after a marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. The population in manufactured-housing dealer overlay notes is the one a marketing mailer that skipped majority-minority tracts named, so Remove access or reverse the item follows for this Redlining and HMDA Data file. 2. The population in manufactured-housing dealer overlay notes is adjacent only to a marketing mailer that skipped majority-minority tracts; Temporary compensating control is the honest Fair Lending call. 3. A credit union rolling out a special-purpose credit program already contained a marketing mailer that skipped majority-minority tracts before manufactured-housing dealer overlay notes arrived; no new Redlining and HMDA Data path. 4. Provenance on manufactured-housing dealer overlay notes after a marketing mailer that skipped majority-minority tracts is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in manufactured-housing dealer overlay notes. 2. Check HMDA coding and underwriting policy against line assignments have a. 3. Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts. 4. For this Fair Lending Redlining and HMDA Data file, read manufactured-housing dealer overlay notes against a marketing mailer that skipped majority-minority tracts and write the one fact that would move line assignments have a for model-risk partner for credit scoring.

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 (manufactured-housing dealer overlay notes after a marketing mailer that skipped majority-minority tracts). If manufactured-housing dealer overlay notes cannot force a Fair Lending label under Redlining and HMDA Data, stop. If manufactured-housing dealer overlay notes after a marketing mailer that skipped majority-minority tracts cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Redlining and HMDA Data close, model-risk partner for credit scoring must do not infer a control or scheme beyond the transaction and entitlement evidence.