Assess whether comparative files show second-review bias (e9b82d)

Situation

A bank with thin HMDA LAR quality cannot treat an underwriter chat that used coded language as color commentary on small-business decline comparative file set for this Fair Lending Examination and Notices comparative files show second-review. CRA strategist must close comparative files show second-review from that extract under Fair Lending / Examination and Notices.

Decision

CRA strategist 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 small-business decline comparative file set after an underwriter chat that used coded language.

Hypotheses to test

• Authorize Remove access or reverse the item now; small-business decline comparative file set already has the discriminator after an underwriter chat that used coded language.
• Keep Temporary compensating control in force until small-business decline comparative file set is completed after an underwriter chat that used coded language for CRA strategist.
• Treat small-business decline comparative file set as Approve a documented exception because both readings appear after an underwriter chat that used coded language.
• Refuse a Fair Lending close: CRA strategist does not have the page comparative files show second-review turns on in small-business decline comparative file set.

Analysis required

• Compare small-business decline comparative file set 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 small-business decline comparative file set.
• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• For this Fair Lending Examination and Notices file, read small-business decline comparative file set 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 / Examination and Notices packet (small-business decline comparative file set after an underwriter chat that used coded language). If small-business decline comparative file set cannot force a Fair Lending label under Examination and Notices, stop. If small-business decline comparative file set after an underwriter chat that used coded language cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Examination and Notices close, CRA strategist must do not infer a control or scheme beyond the transaction and entitlement evidence.