Assess whether a redlining pattern exists after controls (8cd10e)

Situation

The desk packet is model-reason-code mapping that does not match notices after an exception rate twice as high for one group after credit controls. Fair-lending officer in an institution preparing for a redlining exam has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices file.

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 model-reason-code mapping that does not match notices after an exception rate twice as high for one group after credit controls.

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 an exception rate twice as high for one group after credit controls.
• Keep Temporary compensating control in force until model-reason-code mapping that does not match notices is completed after an exception rate twice as high for one group after credit controls for fair-lending officer.
• Treat model-reason-code mapping that does not match notices as Approve a documented exception because both readings appear after an exception rate twice as high for one group after credit controls.
• Refuse a Fair Lending close: fair-lending officer does not have the page a redlining pattern exists turns on in model-reason-code mapping that does not match notices.

Analysis required

• Check HMDA coding and underwriting policy against a redlining pattern exists.
• Compare model-reason-code mapping that does not match notices 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 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 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