Assess whether a redlining pattern exists after controls (f31789)

Situation

Second-review underwriter owns a redlining pattern exists inside a credit union rolling out a special-purpose credit program with geographic application and origination heat map as the only packet. A CRA PE that called the assessment area too narrow is what changed the clock 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 geographic application and origination heat map after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• Authorize Remove access or reverse the item now; geographic application and origination heat map already has the discriminator after a CRA PE that called the assessment area too narrow.
• Keep Temporary compensating control in force until geographic application and origination heat map is completed after a CRA PE that called the assessment area too narrow for second-review underwriter.
• Treat geographic application and origination heat map as Approve a documented exception because both readings appear after a CRA PE that called the assessment area too narrow.
• Refuse a Fair Lending close: second-review underwriter does not have the page a redlining pattern exists turns on in geographic application and origination heat map.

Analysis required

• Match the adverse-action language to the facts in geographic application and origination heat map.
• Check HMDA coding and underwriting policy against a redlining pattern exists.
• Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow.
• For this Fair Lending Examination and Notices file, read geographic application and origination heat map against a CRA PE that called the assessment area too narrow and write the one fact that would move a redlining pattern exists for second-review underwriter.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (geographic application and origination heat map after a CRA PE that called the assessment area too narrow). The follow-on Examination and Notices action is what second-review underwriter does next: implement the option, assign an owner, and log the missing fact.