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

SITUATION CRA assessment-area versus lending footprint arrived with a board asking if the bank should settle a matched-pair study for adverse-action notice operations lead. That is a Fair Lending CRA and Special-Purpose Programs decision on line assignments have a in a small-business desk using a new vendor score.

DECISION Adverse-action notice operations lead in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using CRA assessment-area versus lending footprint after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. A board asking if the bank should settle a matched-pair study is noise around an already-controlled CRA and Special-Purpose Programs process in a small-business desk using a new vendor score, given CRA assessment-area versus lending footprint. 2. A board asking if the bank should settle a matched-pair study is the event in CRA assessment-area versus lending footprint that forces Remove access or reverse the item for adverse-action notice operations lead under Fair Lending. 3. CRA assessment-area versus lending footprint shows a one-file miss after a board asking if the bank should settle a matched-pair study, not a CRA and Special-Purpose Programs program failure. 4. CRA assessment-area versus lending footprint cannot decide line assignments have a yet after a board asking if the bank should settle a matched-pair study; hold is the only Fair Lending close a small-business desk using a new vendor score can defend.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in CRA assessment-area versus lending footprint. 2. Check HMDA coding and underwriting policy against line assignments have a. 3. Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study. 4. For this Fair Lending CRA and Special-Purpose Programs file, read CRA assessment-area versus lending footprint 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 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 / CRA and Special-Purpose Programs packet (CRA assessment-area versus lending footprint after a board asking if the bank should settle a matched-pair study). Lead with the Fair Lending option CRA assessment-area versus lending footprint 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 adverse-action notice operations lead in a small-business desk using a new vendor score.