Assess whether a redlining pattern exists after controls after a vendor score

Situation

The desk packet is adverse-action notice principal-reason sample after a vendor score change with no disparate-impact test. Exam-response coordinator in a bank with thin HMDA LAR quality has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data file.

Decision

Exam-response coordinator 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 adverse-action notice principal-reason sample after a vendor score change with no disparate-impact test.

Hypotheses to test

• Authorize Remove access or reverse the item now; adverse-action notice principal-reason sample already has the discriminator after a vendor score change with no disparate-impact test.
• Keep Temporary compensating control in force until adverse-action notice principal-reason sample is completed after a vendor score change with no disparate-impact test for exam-response coordinator.
• Treat adverse-action notice principal-reason sample as Approve a documented exception because both readings appear after a vendor score change with no disparate-impact test.
• Refuse a Fair Lending close: exam-response coordinator does not have the page a redlining pattern exists turns on in adverse-action notice principal-reason sample.

Analysis required

• Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test.
• Flag any disparate-impact table exam-response coordinator cannot explain from adverse-action notice principal-reason sample.
• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• For this Fair Lending Redlining and HMDA Data file, read adverse-action notice principal-reason sample against a vendor score change with no disparate-impact test and write the one fact that would move a redlining pattern exists for exam-response coordinator.

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 (adverse-action notice principal-reason sample after a vendor score change with no disparate-impact test). Lead with the Fair Lending option adverse-action notice principal-reason sample can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for exam-response coordinator in a bank with thin HMDA LAR quality.