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

SITUATION A bank with thin HMDA LAR quality cannot treat a branch that stopped taking applications in one ZIP as incidental context on small-business decline comparative file set. Community-development lender must close line assignments have a from that extract under Fair Lending / Pricing and Credit Limits.

DECISION Community-development lender in a bank with thin HMDA LAR quality 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 branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. Small-business decline comparative file set reads as Remove access or reverse the item once a branch that stopped taking applications in one ZIP is lined up to the same Fair Lending population. 2. Small-business decline comparative file set is closer to Temporary compensating control after a branch that stopped taking applications in one ZIP; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract. 3. Approve a documented exception is still live in small-business decline comparative file set for community-development lender in a bank with thin HMDA LAR quality. 4. Small-business decline comparative file set is missing the fact community-development lender needs after a branch that stopped taking applications in one ZIP; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a bank with thin HMDA LAR quality 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 branch that stopped taking applications in one ZIP and write the one fact that would move line assignments have a for community-development lender.

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 branch that stopped taking applications in one ZIP). The follow-on Pricing and Credit Limits action is what community-development lender 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 community-development lender - Hypothesis scorecard against small-business decline comparative file set: supported / rejected / untestable - Owner and next date for community-development lender in a bank with thin HMDA LAR quality - What changes line assignments have a if a branch that stopped taking applications in one ZIP is later withdrawn