Exam-response coordinator must resolve whether the exam response should

Situation

The desk packet is CRA assessment-area versus lending footprint after a board asking if the bank should settle a matched-pair study. Exam-response coordinator in an institution preparing for a redlining exam has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits file.

Decision

Exam-response coordinator in an institution preparing for a redlining exam 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 board asking if the bank should settle a matched-pair study.

Hypotheses to test

• CRA assessment-area versus lending footprint 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.
• CRA assessment-area versus lending footprint 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 Pricing and Credit Limits extract.
• Approve a documented exception is still live in CRA assessment-area versus lending footprint for exam-response coordinator in an institution preparing for a redlining exam.
• CRA assessment-area versus lending footprint is missing the fact exam-response coordinator needs after a board asking if the bank should settle a matched-pair study; stop this Fair Lending close.

Analysis required

• Check HMDA coding and underwriting policy against the exam response should.
• Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study.
• Flag any disparate-impact table exam-response coordinator cannot explain from CRA assessment-area versus lending footprint.
• For this Fair Lending Pricing and Credit Limits file, read CRA assessment-area versus lending footprint against a board asking if the bank should settle a matched-pair study and write the one fact that would move the exam response should for exam-response coordinator.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (CRA assessment-area versus lending footprint after a board asking if the bank should settle a matched-pair study). If CRA assessment-area versus lending footprint cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent pages an institution preparing for a redlining exam does not have.