Assess whether comparative files show second-review bias (21be3f)

Situation

The desk packet is geographic application and origination heat map after a board asking if the bank should settle a matched-pair study. CRA strategist in an institution preparing for a redlining exam has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending 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 board asking if the bank should settle a matched-pair study.

Hypotheses to test

• The population in geographic application and origination heat map is the one a board asking if the bank should settle a matched-pair study 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 board asking if the bank should settle a matched-pair study; Temporary compensating control is the honest Fair Lending call.
• An institution preparing for a redlining exam already contained a board asking if the bank should settle a matched-pair study 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 board asking if the bank should settle a matched-pair study is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Check HMDA coding and underwriting policy against comparative files show second-review.
• Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study.
• Flag any disparate-impact table CRA strategist cannot explain from geographic application and origination heat map.
• For this Fair Lending Redlining and HMDA Data file, read geographic application and origination heat map against a board asking if the bank should settle a matched-pair study and write the one fact that would move comparative files show second-review for CRA strategist.

Recommendation