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

Situation

After a DOJ or CFPB monitor request for pricing files, underwriting exception log by branch is what community-development lender can touch in a mortgage company after a pricing-regression spike. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Redlining and HMDA Data file.

Decision

Community-development lender 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 underwriting exception log by branch after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• The population in underwriting exception log by branch is the one a DOJ or CFPB monitor request for pricing files named, so Remove access or reverse the item follows for this Redlining and HMDA Data file.
• The population in underwriting exception log by branch is adjacent only to a DOJ or CFPB monitor request for pricing files; Temporary compensating control is the honest Fair Lending call.
• A mortgage company after a pricing-regression spike already contained a DOJ or CFPB monitor request for pricing files before underwriting exception log by branch arrived; no new Redlining and HMDA Data path.
• Provenance on underwriting exception log by branch after a DOJ or CFPB monitor request for pricing files is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Check HMDA coding and underwriting policy against line assignments have a.
• Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files.
• Flag any disparate-impact table community-development lender cannot explain from underwriting exception log by branch.
• For this Fair Lending Redlining and HMDA Data file, read underwriting exception log by branch against a DOJ or CFPB monitor request for pricing files and write the one fact that would move line assignments have a for community-development lender.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (underwriting exception log by branch after a DOJ or CFPB monitor request for pricing files). If underwriting exception log by branch cannot force a Fair Lending label under Redlining and HMDA Data, stop. If underwriting exception log by branch after a DOJ or CFPB monitor request for pricing files cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Redlining and HMDA Data close, community-development lender must do not infer a control or scheme beyond the transaction and entitlement evidence.