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

SITUATION Community-development lender in a mortgage company after a pricing-regression spike has one working extract — HMDA LAR validity and quality edits — after an exception rate twice as high for one group after credit controls. Community-development lender in a mortgage company after a pricing-regression spike has HMDA LAR validity and quality edits after an exception rate twice as high for one group after credit controls. If that extract cannot support line assignments have a, the only defensible Fair Lending Redlining and HMDA Data output is hold.

DECISION Community-development lender 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 HMDA LAR validity and quality edits after an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. Community-development lender can defend Remove access or reverse the item from HMDA LAR validity and quality edits after an exception rate twice as high for one group after credit controls in a Fair Lending challenge. 2. Community-development lender cannot defend Remove access or reverse the item from HMDA LAR validity and quality edits; Temporary compensating control is what the extract actually supports after an exception rate twice as high for one group after credit controls. 3. An exception rate twice as high for one group after credit controls never reached the population in HMDA LAR validity and quality edits — reopen intake, do not close line assignments have a. 4. Two facts in HMDA LAR validity and quality edits after an exception rate twice as high for one group after credit controls conflict for community-development lender; hold this Redlining and HMDA Data file.

ANALYSIS REQUIRED 1. Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls. 2. Flag any disparate-impact table community-development lender cannot explain from HMDA LAR validity and quality edits. 3. Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend. 4. For this Fair Lending Redlining and HMDA Data file, read HMDA LAR validity and quality edits against an exception rate twice as high for one group after credit controls and write the one fact that would move line assignments have a for community-development lender.

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 (HMDA LAR validity and quality edits after an exception rate twice as high for one group after credit controls). If HMDA LAR validity and quality edits cannot force a Fair Lending label under Redlining and HMDA Data, stop. If HMDA LAR validity and quality edits after an exception rate twice as high for one group after credit controls cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Redlining and HMDA Data close, community-development lender must do not infer a control or scheme beyond the transaction and entitlement evidence.