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

SITUATION After a HMDA resubmission that still fails quality edits, model-reason-code mapping that does not match notices is what community-development lender can touch in a bank with thin HMDA LAR quality. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this 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 model-reason-code mapping that does not match notices after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; model-reason-code mapping that does not match notices already has the discriminator after a HMDA resubmission that still fails quality edits. 2. Keep Temporary compensating control in force until model-reason-code mapping that does not match notices is completed after a HMDA resubmission that still fails quality edits for community-development lender. 3. Treat model-reason-code mapping that does not match notices as Approve a documented exception because both readings appear after a HMDA resubmission that still fails quality edits. 4. Refuse a Fair Lending close: community-development lender does not have the decision line assignments have a turns on in model-reason-code mapping that does not match notices.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in model-reason-code mapping that does not match notices. 2. Check HMDA coding and underwriting policy against line assignments have a. 3. Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits. 4. For this Fair Lending Pricing and Credit Limits file, read model-reason-code mapping that does not match notices against a HMDA resubmission that still fails quality edits 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 / Pricing and Credit Limits packet (model-reason-code mapping that does not match notices after a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option model-reason-code mapping that does not match notices can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for community-development lender in a bank with thin HMDA LAR quality.