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

SITUATION Community-development lender is responsible for line assignments have a in a bank, using thin HMDA LAR quality with HMDA LAR validity and quality edits as the only working extract. A branch that stopped taking applications in one ZIP is what reset the timeline for this Fair Lending Pricing and Credit Limits file.

DECISION Community-development lender in a bank with thin HMDA LAR quality must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using HMDA LAR validity and quality edits after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; HMDA LAR validity and quality edits already has the discriminator after a branch that stopped taking applications in one ZIP. 2. Keep Temporary compensating control in force until HMDA LAR validity and quality edits is completed after a branch that stopped taking applications in one ZIP for community-development lender. 3. Treat HMDA LAR validity and quality edits as Approve a documented exception because both readings appear after a branch that stopped taking applications in one ZIP. 4. Refuse a Fair Lending close: community-development lender does not have the decision line assignments have a turns on in HMDA LAR validity and quality edits.

ANALYSIS REQUIRED 1. Flag any disparate-impact table community-development lender cannot explain from HMDA LAR validity and quality edits. 2. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 3. Match the adverse-action language to the facts in HMDA LAR validity and quality edits. 4. For this Fair Lending Pricing and Credit Limits file, read HMDA LAR validity and quality edits against a branch that stopped taking applications in one ZIP and write the one fact that would move line assignments have a for community-development lender.

RECOMMENDATION Release Remove access or reverse the item for this Fair Lending Pricing and Credit Limits file only when HMDA LAR validity and quality edits after a branch that stopped taking applications in one ZIP names the fact line assignments have a requires. Community-development lender in a bank with thin HMDA LAR quality should withhold Remove access or reverse the item while that fact is still a hole in HMDA LAR validity and quality edits.

COMMAND RETURNS - Bottom-line Fair Lending option on line assignments have a, then the evidence in HMDA LAR validity and quality edits, then the action for community-development lender - Hypothesis scorecard against HMDA LAR validity and quality edits: supported / rejected / untestable - Named option among Remove access or reverse the item, Temporary compensating control, Approve a documented exception and the fact that kills the others - Owner and next date for community-development lender in a bank with thin HMDA LAR quality