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

SITUATION In a credit union rolling out a special-purpose credit program, a HMDA resubmission that still fails quality edits put geographic application and origination heat map in play. Adverse-action notice operations lead should decide whether line assignments have a disparate impact the bank will defend without filling gaps geographic application and origination heat map does not contain.

DECISION Adverse-action notice operations lead 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 geographic application and origination heat map after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. Adverse-action notice operations lead can defend Remove access or reverse the item from geographic application and origination heat map after a HMDA resubmission that still fails quality edits in a Fair Lending challenge. 2. Adverse-action notice operations lead cannot defend Remove access or reverse the item from geographic application and origination heat map; Temporary compensating control is what the extract actually supports after a HMDA resubmission that still fails quality edits. 3. A HMDA resubmission that still fails quality edits never reached the population in geographic application and origination heat map — reopen intake, do not close line assignments have a. 4. Two facts in geographic application and origination heat map after a HMDA resubmission that still fails quality edits conflict for adverse-action notice operations lead; hold this Pricing and Credit Limits file.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in geographic application and origination heat map. 2. Check HMDA coding and underwriting policy against line assignments have a. 3. Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits. 4. For this Fair Lending Pricing and Credit Limits file, read geographic application and origination heat map against a HMDA resubmission that still fails quality edits 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 / Pricing and Credit Limits packet (geographic application and origination heat map after a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option geographic application and origination heat map can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for adverse-action notice operations lead in a credit union rolling out a special-purpose credit program.