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

SITUATION A lender expanding into majority-minority census tracts cannot treat a vendor score change with no disparate-impact test as incidental context on SPCP written plan versus actual originations. Adverse-action notice operations lead must close line assignments have a from that extract under Fair Lending / Redlining and HMDA Data.

DECISION Adverse-action notice operations lead 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 vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. A vendor score change with no disparate-impact test is noise around an already-controlled Redlining and HMDA Data process in a lender expanding into majority-minority census tracts, given SPCP written plan versus actual originations. 2. A vendor score change with no disparate-impact test is the event in SPCP written plan versus actual originations that forces Remove access or reverse the item for adverse-action notice operations lead under Fair Lending. 3. SPCP written plan versus actual originations shows a one-file miss after a vendor score change with no disparate-impact test, not a Redlining and HMDA Data program failure. 4. SPCP written plan versus actual originations cannot decide line assignments have a yet after a vendor score change with no disparate-impact test; hold is the only Fair Lending close a lender expanding into majority-minority census tracts can defend.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 2. Match the adverse-action language to the facts in SPCP written plan versus actual originations. 3. Check HMDA coding and underwriting policy against line assignments have a. 4. For this Fair Lending Redlining and HMDA Data file, read SPCP written plan versus actual originations against a vendor score change with no disparate-impact test and write the one fact that would move line assignments have a for adverse-action notice operations lead.

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 vendor score change with no disparate-impact test). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for adverse-action notice operations lead in a lender expanding into majority-minority census tracts.