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

Situation

Community-development lender owns line assignments have a inside a manufactured-housing lender with dealer-originated files with CRA assessment-area versus lending footprint as the only packet. A notice that cites 'other' as the principal reason 40% of the time is what changed the clock for this Fair Lending Examination and Notices file.

Decision

Community-development lender 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 CRA assessment-area versus lending footprint after a notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• Community-development lender can defend Remove access or reverse the item from CRA assessment-area versus lending footprint after a notice that cites 'other' as the principal reason 40% of the time in a Fair Lending challenge.
• Community-development lender cannot defend Remove access or reverse the item from CRA assessment-area versus lending footprint; Temporary compensating control is what the extract actually supports after a notice that cites 'other' as the principal reason 40% of the time.
• A notice that cites 'other' as the principal reason 40% of the time never reached the population in CRA assessment-area versus lending footprint — reopen intake, do not close line assignments have a.
• Two facts in CRA assessment-area versus lending footprint after a notice that cites 'other' as the principal reason 40% of the time conflict for community-development lender; hold this Examination and Notices file.

Analysis required

• Flag any disparate-impact table community-development lender cannot explain from CRA assessment-area versus lending footprint.
• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• Match the adverse-action language to the facts in CRA assessment-area versus lending footprint.
• For this Fair Lending Examination and Notices file, read CRA assessment-area versus lending footprint against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move line assignments have a for community-development lender.

Recommendation