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

SITUATION A CRA PE that called the assessment area too narrow put SPCP written plan versus actual originations in front of model-risk partner for credit scoring in a lender expanding into majority-minority census tracts. This Fair Lending / Examination and Notices close is line assignments have a from SPCP written plan versus actual originations, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

DECISION Model-risk partner for credit scoring in a lender expanding into majority-minority census tracts 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 CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. If Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes holds, SPCP written plan versus actual originations after a CRA PE that called the assessment area too narrow is Remove access or reverse the item for line assignments have a in a lender expanding into majority-minority census tracts. 2. If Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes fails, model-risk partner for credit scoring should take Temporary compensating control on this Fair Lending Examination and Notices packet. 3. Remove access or reverse the item is the Fair Lending Examination and Notices move when SP is premature unless SPCP written plan versus actual originations after a CRA PE that called the assessment area too narrow names the owner for line assignments have a. 4. SPCP written plan versus actual originations is silent on the Examination and Notices discriminator after a CRA PE that called the assessment area too narrow; model-risk partner for credit scoring should not invent a Fair Lending label.

ANALYSIS REQUIRED 1. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow. 2. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from SPCP written plan versus actual originations. 3. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 4. For this Fair Lending Examination and Notices file, read SPCP written plan versus actual originations against a CRA PE that called the assessment area too narrow and write the one fact that would move line assignments have a for model-risk partner for credit scoring.

RECOMMENDATION Remove access or reverse the item is the Fair Lending Examination and Notices move when SPCP written plan versus actual originations lines up with a CRA PE that called the assessment area too narrow for model-risk partner for credit scoring in a lender expanding into majority-minority census tracts. Temporary compensating control is the move when that alignment in SPCP written plan versus actual originations fails. Record the missing fact in SPCP written plan versus actual originations before anyone treats line assignments have a as closed.