Assess whether comparative files show second-review bias (528361)

Situation

Examination and Notices work in a bank with thin HMDA LAR quality now turns on comparative files show second-review because a SPCP that originated almost no loans to the intended class put model-reason-code mapping that does not match notices in play. CRA strategist should say what model-reason-code mapping that does not match notices proves.

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 model-reason-code mapping that does not match notices after a SPCP that originated almost no loans to the intended class.

Hypotheses to test

• Authorize Remove access or reverse the item now; model-reason-code mapping that does not match notices already has the discriminator after a SPCP that originated almost no loans to the intended class.
• Keep Temporary compensating control in force until model-reason-code mapping that does not match notices is completed after a SPCP that originated almost no loans to the intended class for CRA strategist.
• Treat model-reason-code mapping that does not match notices as Approve a documented exception because both readings appear after a SPCP that originated almost no loans to the intended class.
• Refuse a Fair Lending close: CRA strategist does not have the page comparative files show second-review turns on in model-reason-code mapping that does not match notices.

Analysis required

• Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class.
• Flag any disparate-impact table CRA strategist cannot explain from model-reason-code mapping that does not match notices.
• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• For this Fair Lending Examination and Notices file, read model-reason-code mapping that does not match notices against a SPCP that originated almost no loans to the intended class 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 (model-reason-code mapping that does not match notices after a SPCP that originated almost no loans to the intended class). If model-reason-code mapping that does not match notices cannot force a Fair Lending label under Examination and Notices, stop. If model-reason-code mapping that does not match notices after a SPCP that originated almost no loans to the intended class cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Examination and Notices close, CRA strategist must do not infer a control or scheme beyond the transaction and entitlement evidence.