Assess whether a redlining pattern exists after controls (e7df3d)

Situation

The desk packet is CRA assessment-area versus lending footprint after a SPCP that originated almost no loans to the intended class. Exam-response coordinator in a mortgage company after a pricing-regression spike has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices file.

Decision

Exam-response coordinator 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 SPCP that originated almost no loans to the intended class.

Hypotheses to test

• The population in CRA assessment-area versus lending footprint is the one a SPCP that originated almost no loans to the intended class named, so Remove access or reverse the item follows for this Examination and Notices file.
• The population in CRA assessment-area versus lending footprint is adjacent only to a SPCP that originated almost no loans to the intended class; Temporary compensating control is the honest Fair Lending call.
• A mortgage company after a pricing-regression spike already contained a SPCP that originated almost no loans to the intended class before CRA assessment-area versus lending footprint arrived; no new Examination and Notices path.
• Provenance on CRA assessment-area versus lending footprint after a SPCP that originated almost no loans to the intended class is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

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 SPCP that originated almost no loans to the intended class.
• Flag any disparate-impact table exam-response coordinator cannot explain from CRA assessment-area versus lending footprint.
• For this Fair Lending Examination and Notices file, read CRA assessment-area versus lending footprint against a SPCP that originated almost no loans to the intended class and write the one fact that would move a redlining pattern exists for exam-response coordinator.

Recommendation