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

SITUATION After a HMDA resubmission that still fails quality edits, HMDA LAR validity and quality edits is what community-development lender can touch in an institution preparing for a redlining exam. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this CRA and Special-Purpose Programs file.

DECISION Community-development lender in an institution preparing for a redlining exam 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 HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. HMDA LAR validity and quality edits reads as Remove access or reverse the item once a HMDA resubmission that still fails quality edits is lined up to the same Fair Lending population. 2. HMDA LAR validity and quality edits is closer to Temporary compensating control after a HMDA resubmission that still fails quality edits; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract. 3. Approve a documented exception is still live in HMDA LAR validity and quality edits for community-development lender in an institution preparing for a redlining exam. 4. HMDA LAR validity and quality edits is missing the fact community-development lender needs after a HMDA resubmission that still fails quality edits; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against line assignments have a. 2. Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits. 3. Flag any disparate-impact table community-development lender cannot explain from HMDA LAR validity and quality edits. 4. For this Fair Lending CRA and Special-Purpose Programs file, read HMDA LAR validity and quality edits against a HMDA resubmission that still fails quality edits 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 / CRA and Special-Purpose Programs packet (HMDA LAR validity and quality edits after a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option HMDA LAR validity and quality edits can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for community-development lender in an institution preparing for a redlining exam.

COMMAND RETURNS - Bottom-line Fair Lending option on line assignments have a, then the evidence in HMDA LAR validity and quality edits, then the action for community-development lender - Hypothesis scorecard against HMDA LAR validity and quality edits: supported / rejected / untestable - What changes line assignments have a if a HMDA resubmission that still fails quality edits is later withdrawn - Named option among Remove access or reverse the item, Temporary compensating control, Approve a documented exception and the fact that kills the others