Community-development lender must resolve whether notices match the actual

Situation

After an underwriter chat that used coded language, underwriting exception log by branch is what community-development lender can touch in a bank with thin HMDA LAR quality. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this 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 underwriting exception log by branch after an underwriter chat that used coded language.

Hypotheses to test

• The population in underwriting exception log by branch is the one an underwriter chat that used coded language named, so Remove access or reverse the item follows for this Pricing and Credit Limits file.
• The population in underwriting exception log by branch is adjacent only to an underwriter chat that used coded language; Temporary compensating control is the honest Fair Lending call.
• A bank with thin HMDA LAR quality already contained an underwriter chat that used coded language before underwriting exception log by branch arrived; no new Pricing and Credit Limits path.
• Provenance on underwriting exception log by branch after an underwriter chat that used coded language is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language.
• Flag any disparate-impact table community-development lender cannot explain from underwriting exception log by branch.
• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• For this Fair Lending Pricing and Credit Limits file, read underwriting exception log by branch against an underwriter chat that used coded language and write the one fact that would move notices match the actual 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 (underwriting exception log by branch after an underwriter chat that used coded language). The follow-on Pricing and Credit Limits action is what community-development lender does next: implement the option, assign an owner, and log the missing fact.