Assess whether comparative files show second-review bias (98548b)

Situation

The desk packet is geographic application and origination heat map after an underwriter chat that used coded language. Fair-lending officer in a bank with thin HMDA LAR quality has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs file.

Decision

Fair-lending officer in a bank with thin HMDA LAR quality must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using geographic application and origination heat map after an underwriter chat that used coded language.

Hypotheses to test

• An underwriter chat that used coded language is noise around an already-controlled CRA and Special-Purpose Programs process in a bank with thin HMDA LAR quality, given geographic application and origination heat map.
• An underwriter chat that used coded language is the event in geographic application and origination heat map that forces Remove access or reverse the item for fair-lending officer under Fair Lending.
• Geographic application and origination heat map shows a one-file miss after an underwriter chat that used coded language, not a CRA and Special-Purpose Programs program failure.
• Geographic application and origination heat map cannot decide comparative files show second-review yet after an underwriter chat that used coded language; hold is the only Fair Lending close a bank with thin HMDA LAR quality can defend.

Analysis required

• Flag any disparate-impact table fair-lending officer cannot explain from geographic application and origination heat map.
• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• Match the adverse-action language to the facts in geographic application and origination heat map.
• For this Fair Lending CRA and Special-Purpose Programs file, read geographic application and origination heat map against an underwriter chat that used coded language and write the one fact that would move comparative files show second-review for fair-lending officer.

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 (geographic application and origination heat map after an underwriter chat that used coded language). Lead with the Fair Lending option geographic application and origination heat map can support after an underwriter chat that used coded language, then the two facts that force it, then the Monday action for fair-lending officer in a bank with thin HMDA LAR quality.