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

SITUATION In a credit union rolling out a special-purpose credit program, credit-card limit assignment disparity table is the only CRA and Special-Purpose Programs extract after a board asking if the bank should settle a matched-pair study that HMDA data-quality manager can use for line assignments have a. HMDA data-quality manager has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs close using credit-card limit assignment disparity table.

DECISION HMDA data-quality manager in a credit union rolling out a special-purpose credit program must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using credit-card limit assignment disparity table after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; credit-card limit assignment disparity table already has the discriminator after a board asking if the bank should settle a matched-pair study. 2. Keep Temporary compensating control in force until credit-card limit assignment disparity table is completed after a board asking if the bank should settle a matched-pair study for HMDA data-quality manager. 3. Treat credit-card limit assignment disparity table as Approve a documented exception because both readings appear after a board asking if the bank should settle a matched-pair study. 4. Refuse a Fair Lending close: HMDA data-quality manager does not have the decision line assignments have a turns on in credit-card limit assignment disparity table.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against line assignments have a. 2. Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study. 3. Flag any disparate-impact table HMDA data-quality manager cannot explain from credit-card limit assignment disparity table. 4. For this Fair Lending CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table against a board asking if the bank should settle a matched-pair study and write the one fact that would move line assignments have a for HMDA data-quality manager.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (credit-card limit assignment disparity table after a board asking if the bank should settle a matched-pair study). Lead with the Fair Lending option credit-card limit assignment disparity table can support after a board asking if the bank should settle a matched-pair study, then the two facts that force it, then the Monday action for HMDA data-quality manager in a credit union rolling out a special-purpose credit program.