Assess whether the exam response should concede a finding (676cbe)

SITUATION Fair-lending officer in a manufactured-housing lender with dealer-originated files has one working extract — credit-card limit assignment disparity table — after a board asking if the bank should settle a matched-pair study. If credit-card limit assignment disparity table cannot support the exam response should, the only defensible Fair Lending output is hold.

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 a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. Credit-card limit assignment disparity table reads as Remove access or reverse the item once a board asking if the bank should settle a matched-pair study is lined up to the same Fair Lending population. 2. Credit-card limit assignment disparity table is closer to Temporary compensating control after a board asking if the bank should settle a matched-pair study; Remove access or reverse the item would over-claim this Redlining and HMDA Data extract. 3. Approve a documented exception is still live in credit-card limit assignment disparity table for fair-lending officer in a manufactured-housing lender with dealer-originated files. 4. Credit-card limit assignment disparity table is missing the fact fair-lending officer needs after a board asking if the bank should settle a matched-pair study; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Flag any disparate-impact table fair-lending officer cannot explain from credit-card limit assignment disparity table. 2. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 3. Match the adverse-action language to the facts in credit-card limit assignment disparity table. 4. For this Fair Lending Redlining and HMDA Data file, read credit-card limit assignment disparity table against a board asking if the bank should settle a matched-pair study 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 a board asking if the bank should settle a matched-pair study). 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 a board asking if the bank should settle a matched-pair study 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.