Assess whether comparative files show second-review bias (622add)

Situation

Comparative files show second-review sits with exam-response coordinator because a branch that stopped taking applications in one ZIP hit a bank with thin HMDA LAR quality. Evidence is CRA assessment-area versus lending footprint; write the Fair Lending Redlining and HMDA Data option that extract can carry.

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 CRA assessment-area versus lending footprint after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• Exam-response coordinator can defend Remove access or reverse the item from CRA assessment-area versus lending footprint after a branch that stopped taking applications in one ZIP in a Fair Lending challenge.
• Exam-response coordinator cannot defend Remove access or reverse the item from CRA assessment-area versus lending footprint; Temporary compensating control is what the extract actually supports after a branch that stopped taking applications in one ZIP.
• A branch that stopped taking applications in one ZIP never reached the population in CRA assessment-area versus lending footprint — reopen intake, do not close comparative files show second-review.
• Two facts in CRA assessment-area versus lending footprint after a branch that stopped taking applications in one ZIP conflict for exam-response coordinator; hold this Redlining and HMDA Data file.

Analysis required

• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• 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.
• For this Fair Lending Redlining and HMDA Data file, read CRA assessment-area versus lending footprint against a branch that stopped taking applications in one ZIP and write the one fact that would move comparative files show second-review 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 (CRA assessment-area versus lending footprint after a branch that stopped taking applications in one ZIP). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after a branch that stopped taking applications in one ZIP, then the two facts that force it, then the Monday action for exam-response coordinator in a bank with thin HMDA LAR quality.