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

Situation

Manufactured-housing dealer overlay notes arrived with a board asking if the bank should settle a matched-pair study for CRA strategist. That is a Fair Lending Examination and Notices decision on line assignments have a in a bank with thin HMDA LAR quality.

Decision

CRA strategist 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 manufactured-housing dealer overlay notes after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• CRA strategist can defend Remove access or reverse the item from manufactured-housing dealer overlay notes after a board asking if the bank should settle a matched-pair study in a Fair Lending challenge.
• CRA strategist cannot defend Remove access or reverse the item from manufactured-housing dealer overlay notes; Temporary compensating control is what the extract actually supports after a board asking if the bank should settle a matched-pair study.
• A board asking if the bank should settle a matched-pair study never reached the population in manufactured-housing dealer overlay notes — reopen intake, do not close line assignments have a.
• Two facts in manufactured-housing dealer overlay notes after a board asking if the bank should settle a matched-pair study conflict for CRA strategist; hold this Examination and Notices file.

Analysis required

• Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study.
• Flag any disparate-impact table CRA strategist cannot explain from manufactured-housing dealer overlay notes.
• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• For this Fair Lending Examination and Notices file, read manufactured-housing dealer overlay notes 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 CRA strategist.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (manufactured-housing dealer overlay notes after a board asking if the bank should settle a matched-pair study). Lead with the Fair Lending option manufactured-housing dealer overlay notes can support after a board asking if the bank should settle a matched-pair study, then the two facts that force it, then the Monday action for CRA strategist in a bank with thin HMDA LAR quality.