Assess whether comparative files show second-review bias (82b2e7)

Situation

An exception rate twice as high for one group after credit controls put mortgage pricing residual by prohibited-basis group in front of community-development lender in an institution preparing for a redlining exam. This Fair Lending / CRA and Special-Purpose Programs close is comparative files show second-review from mortgage pricing residual by prohibited-basis group, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

Community-development lender 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 mortgage pricing residual by prohibited-basis group after an exception rate twice as high for one group after credit controls.

Hypotheses to test

• Community-development lender can defend Remove access or reverse the item from mortgage pricing residual by prohibited-basis group after an exception rate twice as high for one group after credit controls in a Fair Lending challenge.
• Community-development lender cannot defend Remove access or reverse the item from mortgage pricing residual by prohibited-basis group; Temporary compensating control is what the extract actually supports after an exception rate twice as high for one group after credit controls.
• An exception rate twice as high for one group after credit controls never reached the population in mortgage pricing residual by prohibited-basis group — reopen intake, do not close comparative files show second-review.
• Two facts in mortgage pricing residual by prohibited-basis group after an exception rate twice as high for one group after credit controls conflict for community-development lender; hold this CRA and Special-Purpose Programs file.

Analysis required

• Compare mortgage pricing residual by prohibited-basis group 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 community-development lender cannot explain from mortgage pricing residual by prohibited-basis group.
• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• For this Fair Lending CRA and Special-Purpose Programs file, read mortgage pricing residual by prohibited-basis group against an exception rate twice as high for one group after credit controls and write the one fact that would move comparative files show second-review for community-development lender.