Assess whether comparative files show second-review bias (c94277)

Situation

Comparative files show second-review sits with CRA strategist because a CRA PE that called the assessment area too narrow hit a mortgage company after a pricing-regression spike. Evidence is underwriting exception log by branch; write the Fair Lending CRA and Special-Purpose Programs option that extract can carry.

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 underwriting exception log by branch after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• Underwriting exception log by branch reads as Remove access or reverse the item once a CRA PE that called the assessment area too narrow is lined up to the same Fair Lending population.
• Underwriting exception log by branch is closer to Temporary compensating control after a CRA PE that called the assessment area too narrow; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract.
• Approve a documented exception is still live in underwriting exception log by branch for CRA strategist in a mortgage company after a pricing-regression spike.
• Underwriting exception log by branch is missing the fact CRA strategist needs after a CRA PE that called the assessment area too narrow; stop this Fair Lending close.

Analysis required

• Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow.
• Flag any disparate-impact table CRA strategist cannot explain from underwriting exception log by branch.
• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• For this Fair Lending CRA and Special-Purpose Programs file, read underwriting exception log by branch against a CRA PE that called the assessment area too narrow 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 / CRA and Special-Purpose Programs packet (underwriting exception log by branch after a CRA PE that called the assessment area too narrow). The follow-on CRA and Special-Purpose Programs action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.