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

SITUATION The working file is small-business decline comparative file set after a CRA PE that called the assessment area too narrow. Community-development lender in a bank with thin HMDA LAR quality has to name Remove access or reverse the item or Temporary compensating control 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 small-business decline comparative file set after a CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. The population in small-business decline comparative file set is the one a CRA PE that called the assessment area too narrow named, so Remove access or reverse the item follows for this Pricing and Credit Limits file. 2. The population in small-business decline comparative file set is adjacent only to a CRA PE that called the assessment area too narrow; Temporary compensating control is the honest Fair Lending call. 3. A bank with thin HMDA LAR quality already contained a CRA PE that called the assessment area too narrow before small-business decline comparative file set arrived; no new Pricing and Credit Limits path. 4. Provenance on small-business decline comparative file set after a CRA PE that called the assessment area too narrow is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in small-business decline comparative file set. 2. Check HMDA coding and underwriting policy against line assignments have a. 3. Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow. 4. For this Fair Lending Pricing and Credit Limits file, read small-business decline comparative file set against a CRA PE that called the assessment area too narrow 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 (small-business decline comparative file set after a CRA PE that called the assessment area too narrow). If small-business decline comparative file set cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent missing evidence a bank with thin HMDA LAR quality does not have.

COMMAND RETURNS - Bottom-line Fair Lending option on line assignments have a, then the evidence in small-business decline comparative file set, then the action for community-development lender - Hypothesis scorecard against small-business decline comparative file set: supported / rejected / untestable - Owner and next date for community-development lender in a bank with thin HMDA LAR quality - What changes line assignments have a if a CRA PE that called the assessment area too narrow is later withdrawn