Assess whether the exam response should concede a finding after an exception

SITUATION In a manufactured-housing lender with dealer-originated files, an exception rate twice as high for one group after credit controls put credit-card limit assignment disparity table in play. Fair-lending officer should decide whether the exam response should concede a finding without filling gaps credit-card limit assignment disparity table does not contain.

DECISION Fair-lending officer in a manufactured-housing lender with dealer-originated files must choose Remove access or reverse the item, Temporary compensating control, Approve a documented exception, Hold using credit-card limit assignment disparity table after an exception rate twice as high for one group after credit controls. The question on that file is whether the exam response should concede a finding.

HYPOTHESES TO TEST 1. An exception rate twice as high for one group after credit controls is noise around an already-controlled Redlining and HMDA Data process in a manufactured-housing lender with dealer-originated files, given credit-card limit assignment disparity table. 2. An exception rate twice as high for one group after credit controls is the event in credit-card limit assignment disparity table that forces Remove access or reverse the item for fair-lending officer under Fair Lending. 3. Credit-card limit assignment disparity table shows a one-file miss after an exception rate twice as high for one group after credit controls, not a Redlining and HMDA Data program failure. 4. Credit-card limit assignment disparity table cannot decide the exam response should yet after an exception rate twice as high for one group after credit controls; hold is the only Fair Lending close a manufactured-housing lender with dealer-originated files can defend.

ANALYSIS REQUIRED 1. Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls. 2. Flag any disparate-impact table fair-lending officer cannot explain from credit-card limit assignment disparity table. 3. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 4. For this Fair Lending Redlining and HMDA Data file, read credit-card limit assignment disparity table against an exception rate twice as high for one group after credit controls and write the one fact that would move the exam response should for fair-lending officer.

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 (credit-card limit assignment disparity table after an exception rate twice as high for one group after credit controls). If credit-card limit assignment disparity table cannot force a Fair Lending label under Redlining and HMDA Data, stop. If credit-card limit assignment disparity table after an exception rate twice as high for one group after credit controls cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Redlining and HMDA Data close, fair-lending officer must do not infer a control or scheme beyond the transaction and entitlement evidence.