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

Situation

Fair-lending officer owns line assignments have a inside an institution preparing for a redlining exam with HMDA LAR validity and quality edits as the only packet. A DOJ or CFPB monitor request for pricing files is what changed the clock for this Fair Lending Examination and Notices file.

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 HMDA LAR validity and quality edits after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• Authorize Remove access or reverse the item now; HMDA LAR validity and quality edits already has the discriminator after a DOJ or CFPB monitor request for pricing files.
• Keep Temporary compensating control in force until HMDA LAR validity and quality edits is completed after a DOJ or CFPB monitor request for pricing files for fair-lending officer.
• Treat HMDA LAR validity and quality edits as Approve a documented exception because both readings appear after a DOJ or CFPB monitor request for pricing files.
• Refuse a Fair Lending close: fair-lending officer does not have the page line assignments have a turns on in HMDA LAR validity and quality edits.

Analysis required

• Check HMDA coding and underwriting policy against line assignments have a.
• Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files.
• Flag any disparate-impact table fair-lending officer cannot explain from HMDA LAR validity and quality edits.
• For this Fair Lending Examination and Notices file, read HMDA LAR validity and quality edits against a DOJ or CFPB monitor request for pricing files 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 (HMDA LAR validity and quality edits after a DOJ or CFPB monitor request for pricing files). Lead with the Fair Lending option HMDA LAR validity and quality edits can support after a DOJ or CFPB monitor request for pricing files, then the two facts that force it, then the Monday action for fair-lending officer in an institution preparing for a redlining exam.