Assess whether a redlining pattern exists after controls (8541a6)

Situation

Geographic application and origination heat map arrived with an exception rate twice as high for one group after credit controls for fair-lending officer. That is a Fair Lending Examination and Notices decision on a redlining pattern exists in an institution preparing for a redlining exam.

Decision

Fair-lending officer in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using geographic application and origination heat map after an exception rate twice as high for one group after credit controls.

Hypotheses to test

• Geographic application and origination heat map reads as Remove access or reverse the item once an exception rate twice as high for one group after credit controls is lined up to the same Fair Lending population.
• Geographic application and origination heat map is closer to Temporary compensating control after an exception rate twice as high for one group after credit controls; Remove access or reverse the item would over-claim this Examination and Notices extract.
• Approve a documented exception is still live in geographic application and origination heat map for fair-lending officer in an institution preparing for a redlining exam.
• Geographic application and origination heat map is missing the fact fair-lending officer needs after an exception rate twice as high for one group after credit controls; stop this Fair Lending close.

Analysis required

• 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 an exception rate twice as high for one group after credit controls.
• Flag any disparate-impact table fair-lending officer cannot explain from geographic application and origination heat map.
• For this Fair Lending Examination and Notices file, read geographic application and origination heat map against an exception rate twice as high for one group after credit controls 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 / Examination and Notices packet (geographic application and origination heat map after an exception rate twice as high for one group after credit controls). The follow-on Examination and Notices action is what fair-lending officer does next: implement the option, assign an owner, and log the missing fact.