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

SITUATION In a mortgage company after a pricing-regression spike, HMDA LAR validity and quality edits is the evidence after a CRA PE that called the assessment area too narrow. Fair-lending officer has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits close using HMDA LAR validity and quality edits.

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 HMDA LAR validity and quality edits after a CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. The population in HMDA LAR validity and quality edits is the one a CRA PE that called the assessment area too narrow named, so Remove access or reverse the item follows for this Pricing and Credit Limits file. 2. The population in HMDA LAR validity and quality edits is adjacent only to a CRA PE that called the assessment area too narrow; Temporary compensating control is the honest Fair Lending call. 3. A mortgage company after a pricing-regression spike already contained a CRA PE that called the assessment area too narrow before HMDA LAR validity and quality edits arrived; no new Pricing and Credit Limits path. 4. Provenance on HMDA LAR validity and quality edits after a CRA PE that called the assessment area too narrow is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow. 2. Flag any disparate-impact table fair-lending officer cannot explain from HMDA LAR validity and quality edits. 3. Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend. 4. For this Fair Lending Pricing and Credit Limits file, read HMDA LAR validity and quality edits against a CRA PE that called the assessment area too narrow 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 (HMDA LAR validity and quality edits after a CRA PE that called the assessment area too narrow). The follow-on Pricing and Credit Limits action is what fair-lending officer does next: implement the option, assign an owner, and log the missing fact.

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 fair-lending officer - Hypothesis scorecard against HMDA LAR validity and quality edits: supported / rejected / untestable - Owner and next date for fair-lending officer in a mortgage company after a pricing-regression spike - What changes line assignments have a if a CRA PE that called the assessment area too narrow is later withdrawn