Assess whether a redlining pattern exists after controls (19635d)

Situation

The CRA and Special-Purpose Programs desk packet is credit-card limit assignment disparity table after a branch that stopped taking applications in one ZIP. HMDA data-quality manager 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. HMDA data-quality manager 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 CRA and Special-Purpose Programs file.

Decision

HMDA data-quality manager 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 credit-card limit assignment disparity table after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• A branch that stopped taking applications in one ZIP is noise around an already-controlled CRA and Special-Purpose Programs process in a credit union rolling out a special-purpose credit program, given credit-card limit assignment disparity table.
• A branch that stopped taking applications in one ZIP is the event in credit-card limit assignment disparity table that forces Remove access or reverse the item for HMDA data-quality manager under Fair Lending.
• Credit-card limit assignment disparity table shows a one-file miss after a branch that stopped taking applications in one ZIP, not a CRA and Special-Purpose Programs program failure.
• Credit-card limit assignment disparity table cannot decide a redlining pattern exists yet after a branch that stopped taking applications in one ZIP; hold is the only Fair Lending close a credit union rolling out a special-purpose credit program can defend.

Analysis required

• Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend.
• Match the adverse-action language to the facts in credit-card limit assignment disparity table.
• Check HMDA coding and underwriting policy against a redlining pattern exists.
• For this Fair Lending CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table against a branch that stopped taking applications in one ZIP and write the one fact that would move a redlining pattern exists for HMDA data-quality manager.