Assess whether comparative files show second-review bias (4160c4)

Situation

CRA strategist owns comparative files show second-review inside an institution preparing for a redlining exam with CRA assessment-area versus lending footprint as the only packet. A community complaint about appraisal gaps is what changed the clock for this Fair Lending Redlining and HMDA Data file.

Decision

CRA strategist 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 CRA assessment-area versus lending footprint after a community complaint about appraisal gaps.

Hypotheses to test

• Authorize Remove access or reverse the item now; CRA assessment-area versus lending footprint already has the discriminator after a community complaint about appraisal gaps.
• Keep Temporary compensating control in force until CRA assessment-area versus lending footprint is completed after a community complaint about appraisal gaps for CRA strategist.
• Treat CRA assessment-area versus lending footprint as Approve a documented exception because both readings appear after a community complaint about appraisal gaps.
• Refuse a Fair Lending close: CRA strategist does not have the page comparative files show second-review turns on in CRA assessment-area versus lending footprint.

Analysis required

• Match the adverse-action language to the facts in CRA assessment-area versus lending footprint.
• Check HMDA coding and underwriting policy against comparative files show second-review.
• Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps.
• For this Fair Lending Redlining and HMDA Data file, read CRA assessment-area versus lending footprint against a community complaint about appraisal gaps and write the one fact that would move comparative files show second-review for CRA strategist.

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 (CRA assessment-area versus lending footprint after a community complaint about appraisal gaps). The follow-on Redlining and HMDA Data action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.