Assess whether comparative files show second-review bias (bcef5b)

Situation

Comparative files show second-review sits with community-development lender because a DOJ or CFPB monitor request for pricing files hit an institution preparing for a redlining exam. Evidence is CRA assessment-area versus lending footprint; write the Fair Lending CRA and Special-Purpose Programs option that extract can carry.

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 CRA assessment-area versus lending footprint after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• A DOJ or CFPB monitor request for pricing files is noise around an already-controlled CRA and Special-Purpose Programs process in an institution preparing for a redlining exam, given CRA assessment-area versus lending footprint.
• A DOJ or CFPB monitor request for pricing files is the event in CRA assessment-area versus lending footprint that forces Remove access or reverse the item for community-development lender under Fair Lending.
• CRA assessment-area versus lending footprint shows a one-file miss after a DOJ or CFPB monitor request for pricing files, not a CRA and Special-Purpose Programs program failure.
• CRA assessment-area versus lending footprint cannot decide comparative files show second-review yet after a DOJ or CFPB monitor request for pricing files; 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 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 DOJ or CFPB monitor request for pricing files.
• For this Fair Lending CRA and Special-Purpose Programs file, read CRA assessment-area versus lending footprint against a DOJ or CFPB monitor request for pricing files and write the one fact that would move comparative files show second-review for community-development lender.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (CRA assessment-area versus lending footprint after a DOJ or CFPB monitor request for pricing files). The follow-on CRA and Special-Purpose Programs action is what community-development lender does next: implement the option, assign an owner, and log the missing fact.