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

SITUATION After a HMDA resubmission that still fails quality edits, SPCP written plan versus actual originations is what second-review underwriter can touch in a small-business desk using a new vendor score. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Redlining and HMDA Data file.

DECISION Second-review underwriter in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using SPCP written plan versus actual originations after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; SPCP written plan versus actual originations already has the discriminator after a HMDA resubmission that still fails quality edits. 2. Keep Temporary compensating control in force until SPCP written plan versus actual originations is completed after a HMDA resubmission that still fails quality edits for second-review underwriter. 3. Treat SPCP written plan versus actual originations as Approve a documented exception because both readings appear after a HMDA resubmission that still fails quality edits. 4. Refuse a Fair Lending close: second-review underwriter does not have the decision line assignments have a turns on in SPCP written plan versus actual originations.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in SPCP written plan versus actual originations. 2. Check HMDA coding and underwriting policy against line assignments have a. 3. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits. 4. For this Fair Lending Redlining and HMDA Data file, read SPCP written plan versus actual originations against a HMDA resubmission that still fails quality edits and write the one fact that would move line assignments have a for second-review underwriter.

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 (SPCP written plan versus actual originations after a HMDA resubmission that still fails quality edits). The follow-on Redlining and HMDA Data action is what second-review underwriter 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 SPCP written plan versus actual originations, then the action for second-review underwriter - Hypothesis scorecard against SPCP written plan versus actual originations: supported / rejected / untestable - Regulatory or exam hook Redlining and HMDA Data would cite - Redlining and HMDA Data finding in SPCP written plan versus actual originations that a second reviewer can re-perform