Assess whether a redlining pattern exists after controls from SPCP written

Situation

Pricing and Credit Limits work in a lender expanding into majority-minority census tracts now turns on a redlining pattern exists because a CRA PE that called the assessment area too narrow put SPCP written plan versus actual originations in play. HMDA data-quality manager should say what SPCP written plan versus actual originations proves.

Decision

HMDA data-quality manager in a lender expanding into majority-minority census tracts must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using SPCP written plan versus actual originations after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• The population in SPCP written plan versus actual originations is the one a CRA PE that called the assessment area too narrow named, so Remove access or reverse the item follows for this Pricing and Credit Limits file.
• The population in SPCP written plan versus actual originations is adjacent only to a CRA PE that called the assessment area too narrow; Temporary compensating control is the honest Fair Lending call.
• A lender expanding into majority-minority census tracts already contained a CRA PE that called the assessment area too narrow before SPCP written plan versus actual originations arrived; no new Pricing and Credit Limits path.
• Provenance on SPCP written plan versus actual originations after a CRA PE that called the assessment area too narrow is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Check HMDA coding and underwriting policy against a redlining pattern exists.
• Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow.
• Flag any disparate-impact table HMDA data-quality manager cannot explain from SPCP written plan versus actual originations.
• For this Fair Lending Pricing and Credit Limits file, read SPCP written plan versus actual originations against a CRA PE that called the assessment area too narrow and write the one fact that would move a redlining pattern exists for HMDA data-quality manager.

Recommendation