Assess whether a redlining pattern exists after controls (6229e3)

Situation

A redlining pattern exists sits with fair-lending officer because a branch that stopped taking applications in one ZIP hit a bank with thin HMDA LAR quality. Evidence is geographic application and origination heat map; write the Fair Lending CRA and Special-Purpose Programs option that extract can carry.

Decision

Fair-lending officer in a bank with thin HMDA LAR quality 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 branch that stopped taking applications in one ZIP.

Hypotheses to test

• Authorize Remove access or reverse the item now; geographic application and origination heat map already has the discriminator after a branch that stopped taking applications in one ZIP.
• Keep Temporary compensating control in force until geographic application and origination heat map is completed after a branch that stopped taking applications in one ZIP for fair-lending officer.
• Treat geographic application and origination heat map as Approve a documented exception because both readings appear after a branch that stopped taking applications in one ZIP.
• Refuse a Fair Lending close: fair-lending officer does not have the page a redlining pattern exists turns on in geographic application and origination heat map.

Analysis required

• Flag any disparate-impact table fair-lending officer cannot explain from geographic application and origination heat map.
• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• Match the adverse-action language to the facts in geographic application and origination heat map.
• For this Fair Lending CRA and Special-Purpose Programs file, read geographic application and origination heat map 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 / CRA and Special-Purpose Programs packet (geographic application and origination heat map after a branch that stopped taking applications in one ZIP). The follow-on CRA and Special-Purpose Programs action is what fair-lending officer does next: implement the option, assign an owner, and log the missing fact.