Assess whether comparative files show second-review bias (27bdde)

Situation

CRA strategist owns comparative files show second-review inside an institution preparing for a redlining exam with HMDA LAR validity and quality edits as the only packet. An underwriter chat that used coded language is what changed the clock 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 HMDA LAR validity and quality edits after an underwriter chat that used coded language.

Hypotheses to test

• An underwriter chat that used coded language is noise around an already-controlled Redlining and HMDA Data process in an institution preparing for a redlining exam, given HMDA LAR validity and quality edits.
• An underwriter chat that used coded language is the event in HMDA LAR validity and quality edits that forces Remove access or reverse the item for CRA strategist under Fair Lending.
• HMDA LAR validity and quality edits shows a one-file miss after an underwriter chat that used coded language, not a Redlining and HMDA Data program failure.
• HMDA LAR validity and quality edits cannot decide comparative files show second-review yet after an underwriter chat that used coded language; hold is the only Fair Lending close an institution preparing for a redlining exam can defend.

Analysis required

• Check HMDA coding and underwriting policy against comparative files show second-review.
• Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language.
• Flag any disparate-impact table CRA strategist cannot explain from HMDA LAR validity and quality edits.
• For this Fair Lending Redlining and HMDA Data file, read HMDA LAR validity and quality edits against an underwriter chat that used coded language 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 (HMDA LAR validity and quality edits after an underwriter chat that used coded language). If HMDA LAR validity and quality edits cannot force a Fair Lending label under Redlining and HMDA Data, stop. If HMDA LAR validity and quality edits after an underwriter chat that used coded language cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Redlining and HMDA Data close, CRA strategist must do not infer a control or scheme beyond the transaction and entitlement evidence.