Assess whether a redlining pattern exists after controls (dbf7b7)

Situation

After a DOJ or CFPB monitor request for pricing files, mortgage pricing residual by prohibited-basis group 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 mortgage pricing residual by prohibited-basis group after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• A DOJ or CFPB monitor request for pricing files is noise around an already-controlled Redlining and HMDA Data process in an institution preparing for a redlining exam, given mortgage pricing residual by prohibited-basis group.
• A DOJ or CFPB monitor request for pricing files is the event in mortgage pricing residual by prohibited-basis group that forces Remove access or reverse the item for CRA strategist under Fair Lending.
• Mortgage pricing residual by prohibited-basis group shows a one-file miss after a DOJ or CFPB monitor request for pricing files, not a Redlining and HMDA Data program failure.
• Mortgage pricing residual by prohibited-basis group cannot decide a redlining pattern exists yet after a DOJ or CFPB monitor request for pricing files; hold is the only Fair Lending close an institution preparing for a redlining exam can defend.

Analysis required

• Flag any disparate-impact table CRA strategist 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 Redlining and HMDA Data file, read mortgage pricing residual by prohibited-basis group against a DOJ or CFPB monitor request for pricing files and write the one fact that would move a redlining pattern exists 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 (mortgage pricing residual by prohibited-basis group after a DOJ or CFPB monitor request for pricing files). The follow-on Redlining and HMDA Data action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.