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

SITUATION Adverse-action notice operations lead is responsible for line assignments have a in a small-business desk using a new vendor score, using small-business decline comparative file set as the only working extract. A marketing mailer that skipped majority-minority tracts is what reset the timeline for this Fair Lending CRA and Special-Purpose Programs file.

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 small-business decline comparative file set after a marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; small-business decline comparative file set already has the discriminator after a marketing mailer that skipped majority-minority tracts. 2. Keep Temporary compensating control in force until small-business decline comparative file set is completed after a marketing mailer that skipped majority-minority tracts for adverse-action notice operations lead. 3. Treat small-business decline comparative file set as Approve a documented exception because both readings appear after a marketing mailer that skipped majority-minority tracts. 4. Refuse a Fair Lending close: adverse-action notice operations lead does not have the decision line assignments have a turns on in small-business decline comparative file set.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in small-business decline comparative file set. 2. Check HMDA coding and underwriting policy against line assignments have a. 3. Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts. 4. For this Fair Lending CRA and Special-Purpose Programs file, read small-business decline comparative file set against a marketing mailer that skipped majority-minority tracts 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 (small-business decline comparative file set after a marketing mailer that skipped majority-minority tracts). The follow-on CRA and Special-Purpose Programs action is what adverse-action notice operations lead does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on line assignments have a, then the evidence in small-business decline comparative file set, then the action for adverse-action notice operations lead - Hypothesis scorecard against small-business decline comparative file set: supported / rejected / untestable - What changes line assignments have a if a marketing mailer that skipped majority-minority tracts is later withdrawn - Named option among Remove access or reverse the item, Temporary compensating control, Approve a documented exception and the fact that kills the others