Whether a redlining pattern exists after controls from geographic application

Situation

An institution preparing for a redlining exam cannot treat a vendor score change with no disparate-impact test as color commentary on geographic application and origination heat map. Exam-response coordinator must close a redlining pattern exists from that extract under Fair Lending / Pricing and Credit Limits.

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 geographic application and origination heat map after a vendor score change with no disparate-impact test.

Hypotheses to test

• A vendor score change with no disparate-impact test is noise around an already-controlled Pricing and Credit Limits process in an institution preparing for a redlining exam, given geographic application and origination heat map.
• A vendor score change with no disparate-impact test is the event in geographic application and origination heat map that forces Remove access or reverse the item for exam-response coordinator under Fair Lending.
• Geographic application and origination heat map shows a one-file miss after a vendor score change with no disparate-impact test, not a Pricing and Credit Limits program failure.
• Geographic application and origination heat map cannot decide a redlining pattern exists yet after a vendor score change with no disparate-impact test; hold is the only Fair Lending close an institution preparing for a redlining exam can defend.

Analysis required

• Match the adverse-action language to the facts in geographic application and origination heat map.
• Check HMDA coding and underwriting policy against a redlining pattern exists.
• Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test.
• For this Fair Lending Pricing and Credit Limits file, read geographic application and origination heat map against a vendor score change with no disparate-impact test and write the one fact that would move a redlining pattern exists 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 (geographic application and origination heat map after a vendor score change with no disparate-impact test). If geographic application and origination heat map 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.