CRA strategist must resolve whether a redlining pattern exists after controls

Situation

The desk packet is geographic application and origination heat map after a SPCP that originated almost no loans to the intended class. CRA strategist in a manufactured-housing lender with dealer-originated files has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits file.

Decision

CRA strategist in a manufactured-housing lender with dealer-originated files must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using geographic application and origination heat map after a SPCP that originated almost no loans to the intended class.

Hypotheses to test

• Geographic application and origination heat map reads as Remove access or reverse the item once a SPCP that originated almost no loans to the intended class is lined up to the same Fair Lending population.
• Geographic application and origination heat map is closer to Temporary compensating control after a SPCP that originated almost no loans to the intended class; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract.
• Approve a documented exception is still live in geographic application and origination heat map for CRA strategist in a manufactured-housing lender with dealer-originated files.
• Geographic application and origination heat map is missing the fact CRA strategist needs after a SPCP that originated almost no loans to the intended class; stop this Fair Lending close.

Analysis required

• Flag any disparate-impact table CRA strategist cannot explain from geographic application and origination heat map.
• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• Match the adverse-action language to the facts in geographic application and origination heat map.
• For this Fair Lending Pricing and Credit Limits file, read geographic application and origination heat map against a SPCP that originated almost no loans to the intended class and write the one fact that would move a redlining pattern exists for CRA strategist.

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 (geographic application and origination heat map after a SPCP that originated almost no loans to the intended class). The follow-on Pricing and Credit Limits action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.