Assess whether a redlining pattern exists after controls from CRA

Situation

In a mortgage company after a pricing-regression spike, CRA assessment-area versus lending footprint is the evidence after a branch that stopped taking applications in one ZIP. Fair-lending officer has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits close using CRA assessment-area versus lending footprint.

Decision

Fair-lending officer 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 CRA assessment-area versus lending footprint after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• Fair-lending officer can defend Remove access or reverse the item from CRA assessment-area versus lending footprint after a branch that stopped taking applications in one ZIP in a Fair Lending challenge.
• Fair-lending officer cannot defend Remove access or reverse the item from CRA assessment-area versus lending footprint; Temporary compensating control is what the extract actually supports after a branch that stopped taking applications in one ZIP.
• A branch that stopped taking applications in one ZIP never reached the population in CRA assessment-area versus lending footprint — reopen intake, do not close a redlining pattern exists.
• Two facts in CRA assessment-area versus lending footprint after a branch that stopped taking applications in one ZIP conflict for fair-lending officer; hold this Pricing and Credit Limits file.

Analysis required

• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• Match the adverse-action language to the facts in CRA assessment-area versus lending footprint.
• Check HMDA coding and underwriting policy against a redlining pattern exists.
• For this Fair Lending Pricing and Credit Limits file, read CRA assessment-area versus lending footprint against a branch that stopped taking applications in one ZIP and write the one fact that would move a redlining pattern exists for fair-lending officer.

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 branch that stopped taking applications in one ZIP). The follow-on Pricing and Credit Limits action is what fair-lending officer does next: implement the option, assign an owner, and log the missing fact.