Assess whether a redlining pattern exists after controls (bbf929)

Situation

CRA strategist owns a redlining pattern exists inside a bank with thin HMDA LAR quality with model-reason-code mapping that does not match notices 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

CRA strategist 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 model-reason-code mapping that does not match notices after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• Authorize Remove access or reverse the item now; model-reason-code mapping that does not match notices already has the discriminator after a CRA PE that called the assessment area too narrow.
• Keep Temporary compensating control in force until model-reason-code mapping that does not match notices is completed after a CRA PE that called the assessment area too narrow for CRA strategist.
• Treat model-reason-code mapping that does not match notices 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: CRA strategist does not have the page a redlining pattern exists turns on in model-reason-code mapping that does not match notices.

Analysis required

• Flag any disparate-impact table CRA strategist cannot explain from model-reason-code mapping that does not match notices.
• 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 model-reason-code mapping that does not match notices.
• For this Fair Lending Examination and Notices file, read model-reason-code mapping that does not match notices 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 / Examination and Notices packet (model-reason-code mapping that does not match notices after a CRA PE that called the assessment area too narrow). Lead with the Fair Lending option model-reason-code mapping that does not match notices can support after a CRA PE that called the assessment area too narrow, then the two facts that force it, then the Monday action for CRA strategist in a bank with thin HMDA LAR quality.