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

SITUATION The working file is mortgage pricing residual by prohibited-basis group after a DOJ or CFPB monitor request for pricing files. Community-development lender in a bank with thin HMDA LAR quality has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits file.

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 mortgage pricing residual by prohibited-basis group after a DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; mortgage pricing residual by prohibited-basis group already has the discriminator after a DOJ or CFPB monitor request for pricing files. 2. Keep Temporary compensating control in force until mortgage pricing residual by prohibited-basis group is completed after a DOJ or CFPB monitor request for pricing files for community-development lender. 3. Treat mortgage pricing residual by prohibited-basis group as Approve a documented exception because both readings appear after a DOJ or CFPB monitor request for pricing files. 4. Refuse a Fair Lending close: community-development lender does not have the decision line assignments have a turns on in mortgage pricing residual by prohibited-basis group.

ANALYSIS REQUIRED 1. Flag any disparate-impact table community-development lender cannot explain from mortgage pricing residual by prohibited-basis group. 2. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 3. Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group. 4. For this Fair Lending Pricing and Credit Limits file, read mortgage pricing residual by prohibited-basis group against a DOJ or CFPB monitor request for pricing files 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 (mortgage pricing residual by prohibited-basis group after a DOJ or CFPB monitor request for pricing files). If mortgage pricing residual by prohibited-basis group cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent missing evidence a bank with thin HMDA LAR quality does not have.

COMMAND RETURNS - Bottom-line Fair Lending option on line assignments have a, then the evidence in mortgage pricing residual by prohibited-basis group, then the action for community-development lender - Hypothesis scorecard against mortgage pricing residual by prohibited-basis group: supported / rejected / untestable - Missing page in mortgage pricing residual by prohibited-basis group after a DOJ or CFPB monitor request for pricing files, if any - Regulatory or exam hook Pricing and Credit Limits would cite