Assess whether a redlining pattern exists after controls (a4b906)

Situation

CRA and Special-Purpose Programs work in a small-business desk using a new vendor score now turns on a redlining pattern exists because a board asking if the bank should settle a matched-pair study put HMDA LAR validity and quality edits in play. CRA and Special-Purpose Programs work in a small-business desk using a new vendor score now turns on a redlining pattern exists because a board asking if the bank should settle a matched-pair study put HMDA LAR validity and quality edits in play; adverse-action notice operations lead should say what HMDA LAR validity and quality edits proves for Fair Lending.

Decision

Adverse-action notice operations lead in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using HMDA LAR validity and quality edits after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• The population in HMDA LAR validity and quality edits is the one a board asking if the bank should settle a matched-pair study named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file.
• The population in HMDA LAR validity and quality edits is adjacent only to a board asking if the bank should settle a matched-pair study; Temporary compensating control is the honest Fair Lending call.
• A small-business desk using a new vendor score already contained a board asking if the bank should settle a matched-pair study before HMDA LAR validity and quality edits arrived; no new CRA and Special-Purpose Programs path.
• Provenance on HMDA LAR validity and quality edits after a board asking if the bank should settle a matched-pair study is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study.
• Flag any disparate-impact table adverse-action notice operations lead cannot explain from HMDA LAR validity and quality edits.
• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• For this Fair Lending CRA and Special-Purpose Programs file, read HMDA LAR validity and quality edits against a board asking if the bank should settle a matched-pair study and write the one fact that would move a redlining pattern exists for adverse-action notice operations lead.