Assess whether comparative files show second-review bias (10a99f)

Situation

The CRA and Special-Purpose Programs desk packet is CRA assessment-area versus lending footprint after a board asking if the bank should settle a matched-pair study. HMDA data-quality manager in a credit union rolling out a special-purpose credit program must name Remove access or reverse the item or Temporary compensating control for this Fair Lending file. HMDA data-quality manager in a credit union rolling out a special-purpose credit program has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs file.

Decision

HMDA data-quality manager in a credit union rolling out a special-purpose credit program must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using CRA assessment-area versus lending footprint after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• The population in CRA assessment-area versus lending footprint 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 CRA and Special-Purpose Programs file.
• The population in CRA assessment-area versus lending footprint 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.
• A credit union rolling out a special-purpose credit program already contained a board asking if the bank should settle a matched-pair study before CRA assessment-area versus lending footprint arrived; no new CRA and Special-Purpose Programs path.
• Provenance on CRA assessment-area versus lending footprint 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 CRA assessment-area versus lending footprint 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 HMDA data-quality manager cannot explain from CRA assessment-area versus lending footprint.
• For this Fair Lending CRA and Special-Purpose Programs file, read CRA assessment-area versus lending footprint 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 HMDA data-quality manager.