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

Situation

A HMDA resubmission that still fails quality edits put small-business decline comparative file set in front of adverse-action notice operations lead in a credit-card issuer changing line-assignment logic. This Fair Lending / Examination and Notices close is line assignments have a from small-business decline comparative file set, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

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 small-business decline comparative file set after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• The population in small-business decline comparative file set is the one a HMDA resubmission that still fails quality edits named, so Remove access or reverse the item follows for this Examination and Notices file.
• The population in small-business decline comparative file set is adjacent only to a HMDA resubmission that still fails quality edits; Temporary compensating control is the honest Fair Lending call.
• A credit-card issuer changing line-assignment logic already contained a HMDA resubmission that still fails quality edits before small-business decline comparative file set arrived; no new Examination and Notices path.
• Provenance on small-business decline comparative file set after a HMDA resubmission that still fails quality edits is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Match the adverse-action language to the facts in small-business decline comparative file set.
• Check HMDA coding and underwriting policy against line assignments have a.
• Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits.
• For this Fair Lending Examination and Notices file, read small-business decline comparative file set 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