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

SITUATION In a manufactured-housing lender with dealer-originated files, geographic application and origination heat map is the evidence after an underwriter chat that used coded language. CRA strategist has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits close using geographic application and origination heat map.

DECISION CRA strategist 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 geographic application and origination heat map after an underwriter chat that used coded language.

HYPOTHESES TO TEST 1. The population in geographic application and origination heat map is the one an underwriter chat that used coded language named, so Remove access or reverse the item follows for this Pricing and Credit Limits file. 2. The population in geographic application and origination heat map is adjacent only to an underwriter chat that used coded language; Temporary compensating control is the honest Fair Lending call. 3. A manufactured-housing lender with dealer-originated files already contained an underwriter chat that used coded language before geographic application and origination heat map arrived; no new Pricing and Credit Limits path. 4. Provenance on geographic application and origination heat map after an underwriter chat that used coded language is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against line assignments have a. 2. Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language. 3. Flag any disparate-impact table CRA strategist cannot explain from geographic application and origination heat map. 4. For this Fair Lending Pricing and Credit Limits file, read geographic application and origination heat map against an underwriter chat that used coded language and write the one fact that would move line assignments have a for CRA strategist.

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 (geographic application and origination heat map after an underwriter chat that used coded language). The follow-on Pricing and Credit Limits action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on line assignments have a, then the evidence in geographic application and origination heat map, then the action for CRA strategist - Hypothesis scorecard against geographic application and origination heat map: supported / rejected / untestable - Missing page in geographic application and origination heat map after an underwriter chat that used coded language, if any - Regulatory or exam hook Pricing and Credit Limits would cite