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

Situation

Mortgage pricing residual by prohibited-basis group arrived with a notice that cites 'other' as the principal reason 40% of the time for second-review underwriter. That is a Fair Lending Examination and Notices decision on line assignments have a in a credit union rolling out a special-purpose credit program.

Decision

Second-review underwriter in a credit union rolling out a special-purpose credit program must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using mortgage pricing residual by prohibited-basis group after a notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• A notice that cites 'other' as the principal reason 40% of the time is noise around an already-controlled Examination and Notices process in a credit union rolling out a special-purpose credit program, given mortgage pricing residual by prohibited-basis group.
• A notice that cites 'other' as the principal reason 40% of the time is the event in mortgage pricing residual by prohibited-basis group that forces Remove access or reverse the item for second-review underwriter under Fair Lending.
• Mortgage pricing residual by prohibited-basis group shows a one-file miss after a notice that cites 'other' as the principal reason 40% of the time, not a Examination and Notices program failure.
• Mortgage pricing residual by prohibited-basis group cannot decide line assignments have a yet after a notice that cites 'other' as the principal reason 40% of the time; hold is the only Fair Lending close a credit union rolling out a special-purpose credit program can defend.

Analysis required

• Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time.
• Flag any disparate-impact table second-review underwriter cannot explain from mortgage pricing residual by prohibited-basis group.
• Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend.
• For this Fair Lending Examination and Notices file, read mortgage pricing residual by prohibited-basis group against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move line assignments have a for second-review underwriter.