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

SITUATION Examination and Notices work in a credit union rolling out a special-purpose credit program now turns on line assignments have a because a HMDA resubmission that still fails quality edits put credit-card limit assignment disparity table in play. Second-review underwriter should say what credit-card limit assignment disparity table proves.

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 credit-card limit assignment disparity table after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. The population in credit-card limit assignment disparity table is the one a HMDA resubmission that still fails quality edits named, so Remove access or reverse the item follows for this Examination and Notices file. 2. The population in credit-card limit assignment disparity table is adjacent only to a HMDA resubmission that still fails quality edits; Temporary compensating control is the honest Fair Lending call. 3. A credit union rolling out a special-purpose credit program already contained a HMDA resubmission that still fails quality edits before credit-card limit assignment disparity table arrived; no new Examination and Notices path. 4. Provenance on credit-card limit assignment disparity table after a HMDA resubmission that still fails quality edits 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 credit-card limit assignment disparity table. 2. Check HMDA coding and underwriting policy against line assignments have a. 3. Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits. 4. For this Fair Lending Examination and Notices file, read credit-card limit assignment disparity table against a HMDA resubmission that still fails quality edits 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 (credit-card limit assignment disparity table after a HMDA resubmission that still fails quality edits). The follow-on Examination and Notices action is what second-review underwriter 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 credit-card limit assignment disparity table, then the action for second-review underwriter - Hypothesis scorecard against credit-card limit assignment disparity table: supported / rejected / untestable - Missing page in credit-card limit assignment disparity table after a HMDA resubmission that still fails quality edits, if any - Regulatory or exam hook Examination and Notices would cite