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

SITUATION CRA and Special-Purpose Programs work in a mortgage company after a pricing-regression spike now turns on line assignments have a because a DOJ or CFPB monitor request for pricing files put geographic application and origination heat map in play. CRA and Special-Purpose Programs work in a mortgage company after a pricing-regression spike now turns on line assignments have a because a DOJ or CFPB monitor request for pricing files put geographic application and origination heat map in play; CRA strategist should say what geographic application and origination heat map proves for Fair Lending.

DECISION CRA strategist in a mortgage company after a pricing-regression spike 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 DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. A DOJ or CFPB monitor request for pricing files is noise around an already-controlled CRA and Special-Purpose Programs process in a mortgage company after a pricing-regression spike, given geographic application and origination heat map. 2. A DOJ or CFPB monitor request for pricing files is the event in geographic application and origination heat map that forces Remove access or reverse the item for CRA strategist under Fair Lending. 3. Geographic application and origination heat map shows a one-file miss after a DOJ or CFPB monitor request for pricing files, not a CRA and Special-Purpose Programs program failure. 4. Geographic application and origination heat map cannot decide line assignments have a yet after a DOJ or CFPB monitor request for pricing files; hold is the only Fair Lending close a mortgage company after a pricing-regression spike can defend.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend. 2. Match the adverse-action language to the facts in geographic application and origination heat map. 3. Check HMDA coding and underwriting policy against line assignments have a. 4. For this Fair Lending CRA and Special-Purpose Programs file, read geographic application and origination heat map against a DOJ or CFPB monitor request for pricing files and write the one fact that would move line assignments have a for CRA strategist.

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 (geographic application and origination heat map after a DOJ or CFPB monitor request for pricing files). The follow-on CRA and Special-Purpose Programs action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.