Assess whether comparative files show second-review bias (7c3827)

Situation

The desk packet is HMDA LAR validity and quality edits after a community complaint about appraisal gaps. CRA strategist in a bank with thin HMDA LAR quality has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices file.

Decision

CRA strategist 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 HMDA LAR validity and quality edits after a community complaint about appraisal gaps.

Hypotheses to test

• A community complaint about appraisal gaps is noise around an already-controlled Examination and Notices process in a bank with thin HMDA LAR quality, given HMDA LAR validity and quality edits.
• A community complaint about appraisal gaps is the event in HMDA LAR validity and quality edits that forces Remove access or reverse the item for CRA strategist under Fair Lending.
• HMDA LAR validity and quality edits shows a one-file miss after a community complaint about appraisal gaps, not a Examination and Notices program failure.
• HMDA LAR validity and quality edits cannot decide comparative files show second-review yet after a community complaint about appraisal gaps; hold is the only Fair Lending close a bank with thin HMDA LAR quality can defend.

Analysis required

• Flag any disparate-impact table CRA strategist cannot explain from HMDA LAR validity and quality edits.
• 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 HMDA LAR validity and quality edits.
• For this Fair Lending Examination and Notices file, read HMDA LAR validity and quality edits 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 / Examination and Notices packet (HMDA LAR validity and quality edits after a community complaint about appraisal gaps). Lead with the Fair Lending option HMDA LAR validity and quality edits can support after a community complaint about appraisal gaps, then the two facts that force it, then the Monday action for CRA strategist in a bank with thin HMDA LAR quality.