Assess whether comparative files show second-review bias (312bc0)

Situation

A HMDA resubmission that still fails quality edits put underwriting exception log by branch in front of CRA strategist in a bank with thin HMDA LAR quality. This Fair Lending / Examination and Notices close is comparative files show second-review from underwriting exception log by branch, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

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 underwriting exception log by branch after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• The population in underwriting exception log by branch is the one a HMDA resubmission that still fails quality edits named, so Remove access or reverse the item follows for this Examination and Notices file.
• The population in underwriting exception log by branch is adjacent only to a HMDA resubmission that still fails quality edits; Temporary compensating control is the honest Fair Lending call.
• A bank with thin HMDA LAR quality already contained a HMDA resubmission that still fails quality edits before underwriting exception log by branch arrived; no new Examination and Notices path.
• Provenance on underwriting exception log by branch after a HMDA resubmission that still fails quality edits 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 underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits.
• Flag any disparate-impact table CRA strategist cannot explain from underwriting exception log by branch.
• For this Fair Lending Examination and Notices file, read underwriting exception log by branch against a HMDA resubmission that still fails quality edits 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 (underwriting exception log by branch after a HMDA resubmission that still fails quality edits). The follow-on Examination and Notices action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.