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

SITUATION A SPCP that originated almost no loans to the intended class put geographic application and origination heat map in front of exam-response coordinator in a manufactured-housing lender with dealer-originated files. This Fair Lending / CRA and Special-Purpose Programs close is line assignments have a from geographic application and origination heat map, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

DECISION Exam-response coordinator in a manufactured-housing lender with dealer-originated files 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 SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. A SPCP that originated almost no loans to the intended class is noise around an already-controlled CRA and Special-Purpose Programs process in a manufactured-housing lender with dealer-originated files, given geographic application and origination heat map. 2. A SPCP that originated almost no loans to the intended class is the event in geographic application and origination heat map that forces Remove access or reverse the item for exam-response coordinator under Fair Lending. 3. Geographic application and origination heat map shows a one-file miss after a SPCP that originated almost no loans to the intended class, 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 SPCP that originated almost no loans to the intended class; hold is the only Fair Lending close a manufactured-housing lender with dealer-originated files can defend.

ANALYSIS REQUIRED 1. Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class. 2. Flag any disparate-impact table exam-response coordinator cannot explain from geographic application and origination heat map. 3. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 4. For this Fair Lending CRA and Special-Purpose Programs file, read geographic application and origination heat map against a SPCP that originated almost no loans to the intended class and write the one fact that would move line assignments have a for exam-response coordinator.

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 SPCP that originated almost no loans to the intended class). The follow-on CRA and Special-Purpose Programs action is what exam-response coordinator does next: implement the option, assign an owner, and log the missing fact.