Assess whether a redlining pattern exists after controls (64b5ae)

Situation

HMDA LAR validity and quality edits arrived with a CRA PE that called the assessment area too narrow for CRA strategist. That is a Fair Lending CRA and Special-Purpose Programs decision on a redlining pattern exists in a mortgage company after a pricing-regression spike.

Decision

CRA strategist in a mortgage company after a pricing-regression spike 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 CRA PE that called the assessment area too narrow.

Hypotheses to test

• CRA strategist can defend Remove access or reverse the item from HMDA LAR validity and quality edits after a CRA PE that called the assessment area too narrow in a Fair Lending challenge.
• CRA strategist cannot defend Remove access or reverse the item from HMDA LAR validity and quality edits; Temporary compensating control is what the extract actually supports after a CRA PE that called the assessment area too narrow.
• A CRA PE that called the assessment area too narrow never reached the population in HMDA LAR validity and quality edits — reopen intake, do not close a redlining pattern exists.
• Two facts in HMDA LAR validity and quality edits after a CRA PE that called the assessment area too narrow conflict for CRA strategist; hold this CRA and Special-Purpose Programs file.

Analysis required

• Match the adverse-action language to the facts in HMDA LAR validity and quality edits.
• Check HMDA coding and underwriting policy against a redlining pattern exists.
• Compare HMDA LAR validity and quality edits 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 CRA and Special-Purpose Programs file, read HMDA LAR validity and quality edits against a CRA PE that called the assessment area too narrow and write the one fact that would move a redlining pattern exists for CRA strategist.

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 (HMDA LAR validity and quality edits after a CRA PE that called the assessment area too narrow). If HMDA LAR validity and quality edits cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If HMDA LAR validity and quality edits after a CRA PE that called the assessment area too narrow cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, CRA strategist must do not infer a control or scheme beyond the transaction and entitlement evidence.