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

SITUATION A live Fair Lending Examination and Notices file in a credit-card issuer changing line-assignment logic now turns on adverse-action notice principal-reason sample after a branch that stopped taking applications in one ZIP. Adverse-action notice operations lead should state what that extract proves for whether line assignments have a disparate impact the bank will defend.

DECISION Adverse-action notice operations lead in a credit-card issuer changing line-assignment logic must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using adverse-action notice principal-reason sample after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. Adverse-action notice operations lead can defend Remove access or reverse the item from adverse-action notice principal-reason sample after a branch that stopped taking applications in one ZIP in a Fair Lending challenge. 2. Adverse-action notice operations lead cannot defend Remove access or reverse the item from adverse-action notice principal-reason sample; Temporary compensating control is what the extract actually supports after a branch that stopped taking applications in one ZIP. 3. A branch that stopped taking applications in one ZIP never reached the population in adverse-action notice principal-reason sample — reopen intake, do not close line assignments have a. 4. Two facts in adverse-action notice principal-reason sample after a branch that stopped taking applications in one ZIP conflict for adverse-action notice operations lead; hold this Examination and Notices file.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in adverse-action notice principal-reason sample. 2. Check HMDA coding and underwriting policy against line assignments have a. 3. Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP. 4. For this Fair Lending Examination and Notices file, read adverse-action notice principal-reason sample against a branch that stopped taking applications in one ZIP 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 / Examination and Notices packet (adverse-action notice principal-reason sample after a branch that stopped taking applications in one ZIP). The follow-on Examination and Notices action is what adverse-action notice operations lead does next: implement the option, assign an owner, and log the missing fact.