Assess whether comparative files show second-review bias (f2402b)

Situation

A community complaint about appraisal gaps put geographic application and origination heat map in front of community-development lender in an institution preparing for a redlining exam. This Fair Lending / CRA and Special-Purpose Programs close is comparative files show second-review from geographic application and origination heat map, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

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 geographic application and origination heat map after a community complaint about appraisal gaps.

Hypotheses to test

• A community complaint about appraisal gaps is noise around an already-controlled CRA and Special-Purpose Programs process in an institution preparing for a redlining exam, given geographic application and origination heat map.
• A community complaint about appraisal gaps is the event in geographic application and origination heat map that forces Remove access or reverse the item for community-development lender under Fair Lending.
• Geographic application and origination heat map shows a one-file miss after a community complaint about appraisal gaps, not a CRA and Special-Purpose Programs program failure.
• Geographic application and origination heat map cannot decide comparative files show second-review yet after a community complaint about appraisal gaps; hold is the only Fair Lending close an institution preparing for a redlining exam can defend.

Analysis required

• Match the adverse-action language to the facts in geographic application and origination heat map.
• Check HMDA coding and underwriting policy against comparative files show second-review.
• Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps.
• For this Fair Lending CRA and Special-Purpose Programs file, read geographic application and origination heat map against a community complaint about appraisal gaps and write the one fact that would move comparative files show second-review for community-development lender.