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

Situation

CRA strategist in a bank with thin HMDA LAR quality has one working extract — small-business decline comparative file set — after a DOJ or CFPB monitor request for pricing files. If small-business decline comparative file set cannot support line assignments have a, the honest Fair Lending output is hold.

Decision

CRA strategist 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 DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• Authorize Remove access or reverse the item now; small-business decline comparative file set already has the discriminator after a DOJ or CFPB monitor request for pricing files.
• Keep Temporary compensating control in force until small-business decline comparative file set is completed after a DOJ or CFPB monitor request for pricing files for CRA strategist.
• Treat small-business decline comparative file set as Approve a documented exception because both readings appear after a DOJ or CFPB monitor request for pricing files.
• Refuse a Fair Lending close: CRA strategist does not have the page line assignments have a turns on in small-business decline comparative file set.

Analysis required

• Match the adverse-action language to the facts in small-business decline comparative file set.
• Check HMDA coding and underwriting policy against line assignments have a.
• Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files.
• For this Fair Lending Examination and Notices file, read small-business decline comparative file set against a DOJ or CFPB monitor request for pricing files 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 / Examination and Notices packet (small-business decline comparative file set after a DOJ or CFPB monitor request for pricing files). The follow-on Examination and Notices action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.