Whether comparative files show second-review bias from small-business decline

Situation

In an institution preparing for a redlining exam, small-business decline comparative file set is the evidence after a CRA PE that called the assessment area too narrow. Exam-response coordinator has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits close using small-business decline comparative file set.

Decision

Exam-response coordinator 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 small-business decline comparative file set after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• Exam-response coordinator can defend Remove access or reverse the item from small-business decline comparative file set after a CRA PE that called the assessment area too narrow in a Fair Lending challenge.
• Exam-response coordinator cannot defend Remove access or reverse the item from small-business decline comparative file set; Temporary compensating control is what the extract actually supports after a CRA PE that called the assessment area too narrow.
• A CRA PE that called the assessment area too narrow never reached the population in small-business decline comparative file set — reopen intake, do not close comparative files show second-review.
• Two facts in small-business decline comparative file set after a CRA PE that called the assessment area too narrow conflict for exam-response coordinator; hold this Pricing and Credit Limits file.

Analysis required

• Flag any disparate-impact table exam-response coordinator cannot explain from small-business decline comparative file set.
• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• Match the adverse-action language to the facts in small-business decline comparative file set.
• For this Fair Lending Pricing and Credit Limits file, read small-business decline comparative file set against a CRA PE that called the assessment area too narrow and write the one fact that would move comparative files show second-review for exam-response coordinator.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (small-business decline comparative file set after a CRA PE that called the assessment area too narrow). If small-business decline comparative file set cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent pages an institution preparing for a redlining exam does not have.