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

Situation

Examination and Notices work in a small-business desk using a new vendor score now turns on line assignments have a because a vendor score change with no disparate-impact test put credit-card limit assignment disparity table in play. HMDA data-quality manager should say what credit-card limit assignment disparity table proves.

Decision

HMDA data-quality manager in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using credit-card limit assignment disparity table after a vendor score change with no disparate-impact test.

Hypotheses to test

• Authorize Remove access or reverse the item now; credit-card limit assignment disparity table already has the discriminator after a vendor score change with no disparate-impact test.
• Keep Temporary compensating control in force until credit-card limit assignment disparity table is completed after a vendor score change with no disparate-impact test for HMDA data-quality manager.
• Treat credit-card limit assignment disparity table as Approve a documented exception because both readings appear after a vendor score change with no disparate-impact test.
• Refuse a Fair Lending close: HMDA data-quality manager does not have the page line assignments have a turns on in credit-card limit assignment disparity table.

Analysis required

• Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test.
• Flag any disparate-impact table HMDA data-quality manager cannot explain from credit-card limit assignment disparity table.
• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• For this Fair Lending Examination and Notices file, read credit-card limit assignment disparity table against a vendor score change with no disparate-impact test and write the one fact that would move line assignments have a for HMDA data-quality manager.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (credit-card limit assignment disparity table after a vendor score change with no disparate-impact test). Lead with the Fair Lending option credit-card limit assignment disparity table can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for HMDA data-quality manager in a small-business desk using a new vendor score.