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

SITUATION A mortgage company after a pricing-regression spike cannot treat a SPCP that originated almost no loans to the intended class as incidental context on manufactured-housing dealer overlay notes. Exam-response coordinator must close line assignments have a from that extract under Fair Lending / Examination and Notices.

DECISION Exam-response coordinator in a mortgage company after a pricing-regression spike must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using manufactured-housing dealer overlay notes after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. Manufactured-housing dealer overlay notes reads as Remove access or reverse the item once a SPCP that originated almost no loans to the intended class is lined up to the same Fair Lending population. 2. Manufactured-housing dealer overlay notes is closer to Temporary compensating control after a SPCP that originated almost no loans to the intended class; Remove access or reverse the item would over-claim this Examination and Notices extract. 3. Approve a documented exception is still live in manufactured-housing dealer overlay notes for exam-response coordinator in a mortgage company after a pricing-regression spike. 4. Manufactured-housing dealer overlay notes is missing the fact exam-response coordinator needs after a SPCP that originated almost no loans to the intended class; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class. 2. Flag any disparate-impact table exam-response coordinator cannot explain from manufactured-housing dealer overlay notes. 3. Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend. 4. For this Fair Lending Examination and Notices file, read manufactured-housing dealer overlay notes against a SPCP that originated almost no loans to the intended class and write the one fact that would move line assignments have a for exam-response coordinator.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (manufactured-housing dealer overlay notes after a SPCP that originated almost no loans to the intended class). Lead with the Fair Lending option manufactured-housing dealer overlay notes can support after a SPCP that originated almost no loans to the intended class, then the two facts that force it, then the Monday action for exam-response coordinator in a mortgage company after a pricing-regression spike.