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

Situation

Exam-response coordinator owns line assignments have a inside a mortgage company after a pricing-regression spike with geographic application and origination heat map as the only packet. A community complaint about appraisal gaps is what changed the clock for this Fair Lending Examination and Notices file.

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 geographic application and origination heat map after a community complaint about appraisal gaps.

Hypotheses to test

• A community complaint about appraisal gaps is noise around an already-controlled Examination and Notices process in a mortgage company after a pricing-regression spike, given geographic application and origination heat map.
• A community complaint about appraisal gaps is the event in geographic application and origination heat map that forces Remove access or reverse the item for exam-response coordinator under Fair Lending.
• Geographic application and origination heat map shows a one-file miss after a community complaint about appraisal gaps, not a Examination and Notices program failure.
• Geographic application and origination heat map cannot decide line assignments have a yet after a community complaint about appraisal gaps; hold is the only Fair Lending close a mortgage company after a pricing-regression spike can defend.

Analysis required

• 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.
• Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps.
• For this Fair Lending Examination and Notices file, read geographic application and origination heat map against a community complaint about appraisal gaps 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 (geographic application and origination heat map after a community complaint about appraisal gaps). The follow-on Examination and Notices action is what exam-response coordinator does next: implement the option, assign an owner, and log the missing fact.