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

Situation

In a credit-card issuer changing line-assignment logic, manufactured-housing dealer overlay notes is the evidence after a branch that stopped taking applications in one ZIP. HMDA data-quality manager has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data close using manufactured-housing dealer overlay notes.

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 manufactured-housing dealer overlay notes after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• Manufactured-housing dealer overlay notes reads as Remove access or reverse the item once a branch that stopped taking applications in one ZIP is lined up to the same Fair Lending population.
• Manufactured-housing dealer overlay notes is closer to Temporary compensating control after a branch that stopped taking applications in one ZIP; Remove access or reverse the item would over-claim this Redlining and HMDA Data extract.
• Approve a documented exception is still live in manufactured-housing dealer overlay notes for HMDA data-quality manager in a credit-card issuer changing line-assignment logic.
• Manufactured-housing dealer overlay notes is missing the fact HMDA data-quality manager needs after a branch that stopped taking applications in one ZIP; stop this Fair Lending close.

Analysis required

• Match the adverse-action language to the facts in manufactured-housing dealer overlay notes.
• Check HMDA coding and underwriting policy against line assignments have a.
• Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP.
• For this Fair Lending Redlining and HMDA Data file, read manufactured-housing dealer overlay notes against a branch that stopped taking applications in one ZIP 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 (manufactured-housing dealer overlay notes after a branch that stopped taking applications in one ZIP). The follow-on Redlining and HMDA Data action is what HMDA data-quality manager does next: implement the option, assign an owner, and log the missing fact.