Assess whether a redlining pattern exists after controls (08ddb9)

Situation

In an institution preparing for a redlining exam, mortgage pricing residual by prohibited-basis group is the evidence after a HMDA resubmission that still fails quality edits. Community-development lender has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs close using mortgage pricing residual by prohibited-basis group.

Decision

Community-development lender in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using mortgage pricing residual by prohibited-basis group after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• The population in mortgage pricing residual by prohibited-basis group is the one a HMDA resubmission that still fails quality edits named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file.
• The population in mortgage pricing residual by prohibited-basis group is adjacent only to a HMDA resubmission that still fails quality edits; Temporary compensating control is the honest Fair Lending call.
• An institution preparing for a redlining exam already contained a HMDA resubmission that still fails quality edits before mortgage pricing residual by prohibited-basis group arrived; no new CRA and Special-Purpose Programs path.
• Provenance on mortgage pricing residual by prohibited-basis group after a HMDA resubmission that still fails quality edits is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Flag any disparate-impact table community-development lender cannot explain from mortgage pricing residual by prohibited-basis group.
• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group.
• For this Fair Lending CRA and Special-Purpose Programs file, read mortgage pricing residual by prohibited-basis group against a HMDA resubmission that still fails quality edits and write the one fact that would move a redlining pattern exists for community-development lender.

Recommendation