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

Situation

HMDA data-quality manager in a credit-card issuer changing line-assignment logic has one working extract — credit-card limit assignment disparity table — after a notice that cites 'other' as the principal reason 40% of the time. If credit-card limit assignment disparity table cannot support line assignments have a, the honest Fair Lending output is hold.

Decision

HMDA data-quality manager in a credit-card issuer changing line-assignment logic 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 notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• Authorize Remove access or reverse the item now; credit-card limit assignment disparity table already has the discriminator after a notice that cites 'other' as the principal reason 40% of the time.
• Keep Temporary compensating control in force until credit-card limit assignment disparity table is completed after a notice that cites 'other' as the principal reason 40% of the time for HMDA data-quality manager.
• Treat credit-card limit assignment disparity table as Approve a documented exception because both readings appear after a notice that cites 'other' as the principal reason 40% of the time.
• 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

• Check HMDA coding and underwriting policy against line assignments have a.
• Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time.
• Flag any disparate-impact table HMDA data-quality manager cannot explain from credit-card limit assignment disparity table.
• For this Fair Lending Redlining and HMDA Data file, read credit-card limit assignment disparity table against a notice that cites 'other' as the principal reason 40% of the time 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 / Redlining and HMDA Data packet (credit-card limit assignment disparity table after a notice that cites 'other' as the principal reason 40% of the time). Lead with the Fair Lending option credit-card limit assignment disparity table can support after a notice that cites 'other' as the principal reason 40% of the time, then the two facts that force it, then the Monday action for HMDA data-quality manager in a credit-card issuer changing line-assignment logic.