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

SITUATION An underwriter chat that used coded language put CRA assessment-area versus lending footprint in front of fair-lending officer in a mortgage company after a pricing-regression spike. This Fair Lending / Pricing and Credit Limits close is line assignments have a from CRA assessment-area versus lending footprint, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

DECISION Fair-lending officer in a mortgage company after a pricing-regression spike must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using CRA assessment-area versus lending footprint after an underwriter chat that used coded language.

HYPOTHESES TO TEST 1. Fair-lending officer can defend Remove access or reverse the item from CRA assessment-area versus lending footprint after an underwriter chat that used coded language in a Fair Lending challenge. 2. Fair-lending officer cannot defend Remove access or reverse the item from CRA assessment-area versus lending footprint; Temporary compensating control is what the extract actually supports after an underwriter chat that used coded language. 3. An underwriter chat that used coded language never reached the population in CRA assessment-area versus lending footprint — reopen intake, do not close line assignments have a. 4. Two facts in CRA assessment-area versus lending footprint after an underwriter chat that used coded language conflict for fair-lending officer; hold this Pricing and Credit Limits file.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against line assignments have a. 2. Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language. 3. Flag any disparate-impact table fair-lending officer cannot explain from CRA assessment-area versus lending footprint. 4. For this Fair Lending Pricing and Credit Limits file, read CRA assessment-area versus lending footprint against an underwriter chat that used coded language 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 / Pricing and Credit Limits packet (CRA assessment-area versus lending footprint after an underwriter chat that used coded language). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after an underwriter chat that used coded language, then the two facts that force it, then the Monday action for fair-lending officer in a mortgage company after a pricing-regression spike.