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

SITUATION SPCP written plan versus actual originations arrived with a board asking if the bank should settle a matched-pair study for adverse-action notice operations lead. That is a Fair Lending Redlining and HMDA Data decision on line assignments have a in a lender expanding into majority-minority census tracts.

DECISION Adverse-action notice operations lead in a lender expanding into majority-minority census tracts must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using SPCP written plan versus actual originations after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. The population in SPCP written plan versus actual originations is the one a board asking if the bank should settle a matched-pair study named, so Remove access or reverse the item follows for this Redlining and HMDA Data file. 2. The population in SPCP written plan versus actual originations is adjacent only to a board asking if the bank should settle a matched-pair study; Temporary compensating control is the honest Fair Lending call. 3. A lender expanding into majority-minority census tracts already contained a board asking if the bank should settle a matched-pair study before SPCP written plan versus actual originations arrived; no new Redlining and HMDA Data path. 4. Provenance on SPCP written plan versus actual originations after a board asking if the bank should settle a matched-pair study is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in SPCP written plan versus actual originations. 2. Check HMDA coding and underwriting policy against line assignments have a. 3. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study. 4. For this Fair Lending Redlining and HMDA Data file, read SPCP written plan versus actual originations against a board asking if the bank should settle a matched-pair study 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 / Redlining and HMDA Data packet (SPCP written plan versus actual originations after a board asking if the bank should settle a matched-pair study). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a board asking if the bank should settle a matched-pair study, then the two facts that force it, then the Monday action for adverse-action notice operations lead in a lender expanding into majority-minority census tracts.