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

SITUATION SPCP written plan versus actual originations arrived with a branch that stopped taking applications in one ZIP for community-development lender. That is a Fair Lending Pricing and Credit Limits decision on line assignments have a in a bank with thin HMDA LAR quality.

DECISION Community-development lender in a bank with thin HMDA LAR quality 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 branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; SPCP written plan versus actual originations already has the discriminator after a branch that stopped taking applications in one ZIP. 2. Keep Temporary compensating control in force until SPCP written plan versus actual originations is completed after a branch that stopped taking applications in one ZIP for community-development lender. 3. Treat SPCP written plan versus actual originations as Approve a documented exception because both readings appear after a branch that stopped taking applications in one ZIP. 4. Refuse a Fair Lending close: community-development lender does not have the decision line assignments have a turns on in SPCP written plan versus actual originations.

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 a branch that stopped taking applications in one ZIP. 3. Flag any disparate-impact table community-development lender cannot explain from SPCP written plan versus actual originations. 4. For this Fair Lending Pricing and Credit Limits file, read SPCP written plan versus actual originations against a branch that stopped taking applications in one ZIP and write the one fact that would move line assignments have a for community-development lender.

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 (SPCP written plan versus actual originations after a branch that stopped taking applications in one ZIP). The follow-on Pricing and Credit Limits action is what community-development lender 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 SPCP written plan versus actual originations, then the action for community-development lender - Hypothesis scorecard against SPCP written plan versus actual originations: supported / rejected / untestable - Owner and next date for community-development lender in a bank with thin HMDA LAR quality - What changes line assignments have a if a branch that stopped taking applications in one ZIP is later withdrawn