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

Situation

A bank with thin HMDA LAR quality cannot treat a CRA PE that called the assessment area too narrow as color commentary on CRA assessment-area versus lending footprint. Exam-response coordinator must close line assignments have a from that extract under Fair Lending / Redlining and HMDA Data.

Decision

Exam-response coordinator 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 CRA assessment-area versus lending footprint after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• The population in CRA assessment-area versus lending footprint is the one a CRA PE that called the assessment area too narrow named, so Remove access or reverse the item follows for this Redlining and HMDA Data file.
• The population in CRA assessment-area versus lending footprint is adjacent only to a CRA PE that called the assessment area too narrow; Temporary compensating control is the honest Fair Lending call.
• A bank with thin HMDA LAR quality already contained a CRA PE that called the assessment area too narrow before CRA assessment-area versus lending footprint arrived; no new Redlining and HMDA Data path.
• Provenance on CRA assessment-area versus lending footprint 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

• Match the adverse-action language to the facts in CRA assessment-area versus lending footprint.
• Check HMDA coding and underwriting policy against line assignments have a.
• Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow.
• For this Fair Lending Redlining and HMDA Data file, read CRA assessment-area versus lending footprint against a CRA PE that called the assessment area too narrow 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 / Redlining and HMDA Data packet (CRA assessment-area versus lending footprint after a CRA PE that called the assessment area too narrow). The follow-on Redlining and HMDA Data action is what exam-response coordinator does next: implement the option, assign an owner, and log the missing fact.