Assess whether a redlining pattern exists after controls (1e2cbc)

Situation

A marketing mailer that skipped majority-minority tracts put geographic application and origination heat map in front of second-review underwriter in a lender expanding into majority-minority census tracts. This Fair Lending / CRA and Special-Purpose Programs close is a redlining pattern exists from geographic application and origination heat map, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

Second-review underwriter in a lender expanding into majority-minority census tracts 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 marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• The population in geographic application and origination heat map is the one a marketing mailer that skipped majority-minority tracts named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file.
• The population in geographic application and origination heat map is adjacent only to a marketing mailer that skipped majority-minority tracts; Temporary compensating control is the honest Fair Lending call.
• A lender expanding into majority-minority census tracts already contained a marketing mailer that skipped majority-minority tracts before geographic application and origination heat map arrived; no new CRA and Special-Purpose Programs path.
• Provenance on geographic application and origination heat map after a marketing mailer that skipped majority-minority tracts is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

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 marketing mailer that skipped majority-minority tracts.
• For this Fair Lending CRA and Special-Purpose Programs file, read geographic application and origination heat map against a marketing mailer that skipped majority-minority tracts and write the one fact that would move a redlining pattern exists for second-review underwriter.