Whether a redlining pattern exists after controls from CRA assessment-area

Situation

A redlining pattern exists sits with fair-lending officer because a board asking if the bank should settle a matched-pair study hit a mortgage company after a pricing-regression spike. Evidence is CRA assessment-area versus lending footprint; write the Fair Lending Pricing and Credit Limits option that extract can carry.

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 board asking if the bank should settle a matched-pair study.

Hypotheses to test

• Fair-lending officer can defend Remove access or reverse the item from CRA assessment-area versus lending footprint after a board asking if the bank should settle a matched-pair study 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 board asking if the bank should settle a matched-pair study.
• A board asking if the bank should settle a matched-pair study 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 board asking if the bank should settle a matched-pair study conflict for fair-lending officer; hold this Pricing and Credit Limits file.

Analysis required

• Check HMDA coding and underwriting policy against a redlining pattern exists.
• 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 fair-lending officer 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 a redlining pattern exists for fair-lending officer.

Recommendation