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

Situation

Line assignments have a sits with second-review underwriter because a branch that stopped taking applications in one ZIP hit a credit union rolling out a special-purpose credit program. Evidence is CRA assessment-area versus lending footprint; write the Fair Lending Examination and Notices option that extract can carry.

Decision

Second-review underwriter 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 CRA assessment-area versus lending footprint after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• Second-review underwriter can defend Remove access or reverse the item from CRA assessment-area versus lending footprint after a branch that stopped taking applications in one ZIP in a Fair Lending challenge.
• Second-review underwriter cannot defend Remove access or reverse the item from CRA assessment-area versus lending footprint; Temporary compensating control is what the extract actually supports after a branch that stopped taking applications in one ZIP.
• A branch that stopped taking applications in one ZIP never reached the population in CRA assessment-area versus lending footprint — reopen intake, do not close line assignments have a.
• Two facts in CRA assessment-area versus lending footprint after a branch that stopped taking applications in one ZIP conflict for second-review underwriter; hold this Examination and Notices file.

Analysis required

• Check HMDA coding and underwriting policy against line assignments have a.
• Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP.
• Flag any disparate-impact table second-review underwriter cannot explain from CRA assessment-area versus lending footprint.
• For this Fair Lending Examination and Notices file, read CRA assessment-area versus lending footprint against a branch that stopped taking applications in one ZIP and write the one fact that would move line assignments have a for second-review underwriter.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (CRA assessment-area versus lending footprint after a branch that stopped taking applications in one ZIP). If CRA assessment-area versus lending footprint cannot force a Fair Lending label under Examination and Notices, stop. Do not invent pages a credit union rolling out a special-purpose credit program does not have.