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

SITUATION An underwriter chat that used coded language put SPCP written plan versus actual originations in front of adverse-action notice operations lead in a small-business desk using a new vendor score. This Fair Lending / CRA and Special-Purpose Programs close is line assignments have a from SPCP written plan versus actual originations, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

DECISION Adverse-action notice operations lead 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 SPCP written plan versus actual originations after an underwriter chat that used coded language.

HYPOTHESES TO TEST 1. SPCP written plan versus actual originations reads as Remove access or reverse the item once an underwriter chat that used coded language is lined up to the same Fair Lending population. 2. SPCP written plan versus actual originations is closer to Temporary compensating control after an underwriter chat that used coded language; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract. 3. Approve a documented exception is still live in SPCP written plan versus actual originations for adverse-action notice operations lead in a small-business desk using a new vendor score. 4. SPCP written plan versus actual originations is missing the fact adverse-action notice operations lead needs after an underwriter chat that used coded language; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against line assignments have a. 2. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language. 3. Flag any disparate-impact table adverse-action notice operations lead cannot explain from SPCP written plan versus actual originations. 4. For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations against an underwriter chat that used coded language and write the one fact that would move line assignments have a for adverse-action notice operations lead.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (SPCP written plan versus actual originations after an underwriter chat that used coded language). Lead with the Fair Lending option SPCP written plan versus actual originations can support after an underwriter chat that used coded language, then the two facts that force it, then the Monday action for adverse-action notice operations lead in a small-business desk using a new vendor score.