Assess whether a redlining pattern exists after controls (54a6b7)

Situation

CRA assessment-area versus lending footprint arrived with a CRA PE that called the assessment area too narrow for adverse-action notice operations lead. That is a Fair Lending CRA and Special-Purpose Programs decision on a redlining pattern exists in a small-business desk using a new vendor score.

Decision

Adverse-action notice operations lead in a small-business desk using a new vendor score 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 CRA PE that called the assessment area too narrow.

Hypotheses to test

• Adverse-action notice operations lead can defend Remove access or reverse the item from CRA assessment-area versus lending footprint after a CRA PE that called the assessment area too narrow in a Fair Lending challenge.
• Adverse-action notice operations lead cannot defend Remove access or reverse the item from CRA assessment-area versus lending footprint; 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 CRA assessment-area versus lending footprint — reopen intake, do not close a redlining pattern exists.
• Two facts in CRA assessment-area versus lending footprint after a CRA PE that called the assessment area too narrow conflict for adverse-action notice operations lead; hold this CRA and Special-Purpose Programs file.

Analysis required

• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• Match the adverse-action language to the facts in CRA assessment-area versus lending footprint.
• Check HMDA coding and underwriting policy against a redlining pattern exists.
• For this Fair Lending CRA and Special-Purpose Programs file, read CRA assessment-area versus lending footprint against a CRA PE that called the assessment area too narrow and write the one fact that would move a redlining pattern exists for adverse-action notice operations lead.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (CRA assessment-area versus lending footprint after a CRA PE that called the assessment area too narrow). If CRA assessment-area versus lending footprint cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If CRA assessment-area versus lending footprint after a CRA PE that called the assessment area too narrow cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, adverse-action notice operations lead must do not infer a control or scheme beyond the transaction and entitlement evidence.