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

Situation

A CRA PE that called the assessment area too narrow put geographic application and origination heat map in front of fair-lending officer in an institution preparing for a redlining exam. This Fair Lending / Examination and Notices close is line assignments have a from geographic application and origination heat map, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

Fair-lending officer in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using geographic application and origination heat map after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• Authorize Remove access or reverse the item now; geographic application and origination heat map already has the discriminator after a CRA PE that called the assessment area too narrow.
• Keep Temporary compensating control in force until geographic application and origination heat map is completed after a CRA PE that called the assessment area too narrow for fair-lending officer.
• Treat geographic application and origination heat map as Approve a documented exception because both readings appear after a CRA PE that called the assessment area too narrow.
• Refuse a Fair Lending close: fair-lending officer does not have the page line assignments have a turns on in geographic application and origination heat map.

Analysis required

• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• Match the adverse-action language to the facts in geographic application and origination heat map.
• Check HMDA coding and underwriting policy against line assignments have a.
• For this Fair Lending Examination and Notices file, read geographic application and origination heat map against a CRA PE that called the assessment area too narrow and write the one fact that would move line assignments have a for fair-lending officer.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (geographic application and origination heat map after a CRA PE that called the assessment area too narrow). The follow-on Examination and Notices action is what fair-lending officer does next: implement the option, assign an owner, and log the missing fact.