Assess whether a redlining pattern exists after controls (9cb54f)

Situation

The Examination and Notices desk packet is adverse-action notice principal-reason sample after a board asking if the bank should settle a matched-pair study. Second-review underwriter in a credit union rolling out a special-purpose credit program must name Remove access or reverse the item or Temporary compensating control for this Fair Lending file. Second-review underwriter in a credit union rolling out a special-purpose credit program has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices file.

Decision

Second-review underwriter in a credit union rolling out a special-purpose credit program must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using adverse-action notice principal-reason sample after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• Authorize Remove access or reverse the item now; adverse-action notice principal-reason sample already has the discriminator after a board asking if the bank should settle a matched-pair study.
• Keep Temporary compensating control in force until adverse-action notice principal-reason sample is completed after a board asking if the bank should settle a matched-pair study for second-review underwriter.
• Treat adverse-action notice principal-reason sample as Approve a documented exception because both readings appear after a board asking if the bank should settle a matched-pair study.
• Refuse a Fair Lending close: second-review underwriter does not have the page a redlining pattern exists turns on in adverse-action notice principal-reason sample.

Analysis required

• Check HMDA coding and underwriting policy against a redlining pattern exists.
• Compare adverse-action notice principal-reason sample 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 second-review underwriter cannot explain from adverse-action notice principal-reason sample.
• For this Fair Lending Examination and Notices file, read adverse-action notice principal-reason sample against a board asking if the bank should settle a matched-pair study and write the one fact that would move a redlining pattern exists for second-review underwriter.