Whether comparative files show second-review bias from geographic application

Situation

After a HMDA resubmission that still fails quality edits, geographic application and origination heat map is what CRA strategist can touch in an institution preparing for a redlining exam. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Redlining and HMDA Data file.

Decision

CRA strategist 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 geographic application and origination heat map after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• The population in geographic application and origination heat map is the one a HMDA resubmission that still fails quality edits named, so Remove access or reverse the item follows for this Redlining and HMDA Data file.
• The population in geographic application and origination heat map is adjacent only to a HMDA resubmission that still fails quality edits; Temporary compensating control is the honest Fair Lending call.
• An institution preparing for a redlining exam already contained a HMDA resubmission that still fails quality edits before geographic application and origination heat map arrived; no new Redlining and HMDA Data path.
• Provenance on geographic application and origination heat map after a HMDA resubmission that still fails quality edits is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits.
• Flag any disparate-impact table CRA strategist cannot explain from geographic application and origination heat map.
• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• For this Fair Lending Redlining and HMDA Data file, read geographic application and origination heat map against a HMDA resubmission that still fails quality edits and write the one fact that would move comparative files show second-review for CRA strategist.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (geographic application and origination heat map after a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option geographic application and origination heat map can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for CRA strategist in an institution preparing for a redlining exam.