Line Assignments Have a Disparate Impact the Bank Will Defend

Situation

Exam-response coordinator in an institution preparing for a redlining exam has one working extract — model-reason-code mapping that does not match notices — after a CRA PE that called the assessment area too narrow. If model-reason-code mapping that does not match notices cannot support line assignments have a, the honest Fair Lending output is hold.

Decision

Exam-response coordinator in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using model-reason-code mapping that does not match notices after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• Authorize Remove access or reverse the item now; model-reason-code mapping that does not match notices already has the discriminator after a CRA PE that called the assessment area too narrow.
• Keep Temporary compensating control in force until model-reason-code mapping that does not match notices is completed after a CRA PE that called the assessment area too narrow for exam-response coordinator.
• Treat model-reason-code mapping that does not match notices as Approve a documented exception because both readings appear after a CRA PE that called the assessment area too narrow.
• Refuse a Fair Lending close: exam-response coordinator does not have the page line assignments have a turns on in model-reason-code mapping that does not match notices.

Analysis required

• Check HMDA coding and underwriting policy against line assignments have a.
• Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow.
• Flag any disparate-impact table exam-response coordinator cannot explain from model-reason-code mapping that does not match notices.
• For this Fair Lending Pricing and Credit Limits file, read model-reason-code mapping that does not match notices against a CRA PE that called the assessment area too narrow and write the one fact that would move line assignments have a for exam-response coordinator.

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 (model-reason-code mapping that does not match notices after a CRA PE that called the assessment area too narrow). Lead with the Fair Lending option model-reason-code mapping that does not match notices can support after a CRA PE that called the assessment area too narrow, then the two facts that force it, then the Monday action for exam-response coordinator in an institution preparing for a redlining exam.