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

SITUATION A board asking if the bank should settle a matched-pair study put HMDA LAR validity and quality edits in front of fair-lending officer in a bank with thin HMDA LAR quality. This Fair Lending / CRA and Special-Purpose Programs close is line assignments have a from HMDA LAR validity and quality edits, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

DECISION Fair-lending officer in a bank with thin HMDA LAR quality must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using HMDA LAR validity and quality edits after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. The population in HMDA LAR validity and quality edits is the one a board asking if the bank should settle a matched-pair study named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file. 2. The population in HMDA LAR validity and quality edits is adjacent only to a board asking if the bank should settle a matched-pair study; Temporary compensating control is the honest Fair Lending call. 3. A bank with thin HMDA LAR quality already contained a board asking if the bank should settle a matched-pair study before HMDA LAR validity and quality edits arrived; no new CRA and Special-Purpose Programs path. 4. Provenance on HMDA LAR validity and quality edits after a board asking if the bank should settle a matched-pair study is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study. 2. Flag any disparate-impact table fair-lending officer cannot explain from HMDA LAR validity and quality edits. 3. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 4. For this Fair Lending CRA and Special-Purpose Programs file, read HMDA LAR validity and quality edits against a board asking if the bank should settle a matched-pair study and write the one fact that would move line assignments have a for fair-lending officer.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (HMDA LAR validity and quality edits after a board asking if the bank should settle a matched-pair study). The follow-on CRA and Special-Purpose Programs action is what fair-lending officer does next: implement the option, assign an owner, and log the missing fact.