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

Situation

Redlining and HMDA Data work in a manufactured-housing lender with dealer-originated files now turns on line assignments have a because an underwriter chat that used coded language put small-business decline comparative file set in play. Fair-lending officer should say what small-business decline comparative file set proves.

Decision

Fair-lending officer in a manufactured-housing lender with dealer-originated files must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using small-business decline comparative file set after an underwriter chat that used coded language.

Hypotheses to test

• Authorize Remove access or reverse the item now; small-business decline comparative file set already has the discriminator after an underwriter chat that used coded language.
• Keep Temporary compensating control in force until small-business decline comparative file set is completed after an underwriter chat that used coded language for fair-lending officer.
• Treat small-business decline comparative file set as Approve a documented exception because both readings appear after an underwriter chat that used coded language.
• Refuse a Fair Lending close: fair-lending officer does not have the page line assignments have a turns on in small-business decline comparative file set.

Analysis required

• Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language.
• Flag any disparate-impact table fair-lending officer cannot explain from small-business decline comparative file set.
• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• For this Fair Lending Redlining and HMDA Data file, read small-business decline comparative file set against an underwriter chat that used coded language 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 / Redlining and HMDA Data packet (small-business decline comparative file set after an underwriter chat that used coded language). If small-business decline comparative file set cannot force a Fair Lending label under Redlining and HMDA Data, stop. If small-business decline comparative file set after an underwriter chat that used coded language cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Redlining and HMDA Data close, fair-lending officer must do not infer a control or scheme beyond the transaction and entitlement evidence.