Assess whether comparative files show second-review bias (3ecc43)

Situation

Mortgage pricing residual by prohibited-basis group arrived with a CRA PE that called the assessment area too narrow for community-development lender. That is a Fair Lending CRA and Special-Purpose Programs decision on comparative files show second-review in an institution preparing for a redlining exam.

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 a CRA PE that called the assessment area too narrow.

Hypotheses to test

• The population in mortgage pricing residual by prohibited-basis group is the one a CRA PE that called the assessment area too narrow named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file.
• The population in mortgage pricing residual by prohibited-basis group is adjacent only to a CRA PE that called the assessment area too narrow; Temporary compensating control is the honest Fair Lending call.
• An institution preparing for a redlining exam already contained a CRA PE that called the assessment area too narrow before mortgage pricing residual by prohibited-basis group arrived; no new CRA and Special-Purpose Programs path.
• Provenance on mortgage pricing residual by prohibited-basis group 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

• 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.
• Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group.
• For this Fair Lending CRA and Special-Purpose Programs file, read mortgage pricing residual by prohibited-basis group against a CRA PE that called the assessment area too narrow and write the one fact that would move comparative files show second-review for community-development lender.

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 (mortgage pricing residual by prohibited-basis group after a CRA PE that called the assessment area too narrow). Lead with the Fair Lending option mortgage pricing residual by prohibited-basis group 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 community-development lender in an institution preparing for a redlining exam.