Assess whether comparative files show second-review bias (4a0657)

Situation

In a mortgage company after a pricing-regression spike, SPCP written plan versus actual originations is the evidence after a board asking if the bank should settle a matched-pair study. CRA strategist has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs close using SPCP written plan versus actual originations.

Decision

CRA strategist in a mortgage company after a pricing-regression spike must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using SPCP written plan versus actual originations after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• SPCP written plan versus actual originations reads as Remove access or reverse the item once a board asking if the bank should settle a matched-pair study is lined up to the same Fair Lending population.
• SPCP written plan versus actual originations is closer to Temporary compensating control after a board asking if the bank should settle a matched-pair study; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract.
• Approve a documented exception is still live in SPCP written plan versus actual originations for CRA strategist in a mortgage company after a pricing-regression spike.
• SPCP written plan versus actual originations is missing the fact CRA strategist needs after a board asking if the bank should settle a matched-pair study; stop this Fair Lending close.

Analysis required

• Match the adverse-action language to the facts in SPCP written plan versus actual originations.
• Check HMDA coding and underwriting policy against comparative files show second-review.
• Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study.
• For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations against a board asking if the bank should settle a matched-pair study and write the one fact that would move comparative files show second-review for CRA strategist.

Recommendation