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

SITUATION After a CRA PE that called the assessment area too narrow, underwriting exception log by branch is what second-review underwriter can touch in a small-business desk using a new vendor score. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Redlining and HMDA Data file.

DECISION Second-review underwriter in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using underwriting exception log by branch after a CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. Underwriting exception log by branch reads as Remove access or reverse the item once a CRA PE that called the assessment area too narrow is lined up to the same Fair Lending population. 2. Underwriting exception log by branch is closer to Temporary compensating control after a CRA PE that called the assessment area too narrow; Remove access or reverse the item would over-claim this Redlining and HMDA Data extract. 3. Approve a documented exception is still live in underwriting exception log by branch for second-review underwriter in a small-business desk using a new vendor score. 4. Underwriting exception log by branch is missing the fact second-review underwriter needs after a CRA PE that called the assessment area too narrow; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against line assignments have a. 2. Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow. 3. Flag any disparate-impact table second-review underwriter cannot explain from underwriting exception log by branch. 4. For this Fair Lending Redlining and HMDA Data file, read underwriting exception log by branch against a CRA PE that called the assessment area too narrow and write the one fact that would move line assignments have a for second-review underwriter.

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 (underwriting exception log by branch after a CRA PE that called the assessment area too narrow). Lead with the Fair Lending option underwriting exception log by branch can support after a CRA PE that called the assessment area too narrow, then the two facts that force it, then the Monday action for second-review underwriter in a small-business desk using a new vendor score.

COMMAND RETURNS - Bottom-line Fair Lending option on line assignments have a, then the evidence in underwriting exception log by branch, then the action for second-review underwriter - Hypothesis scorecard against underwriting exception log by branch: supported / rejected / untestable - Owner and next date for second-review underwriter in a small-business desk using a new vendor score - What changes line assignments have a if a CRA PE that called the assessment area too narrow is later withdrawn