Assess whether a redlining pattern exists after controls (ba7fb0)

Situation

Geographic application and origination heat map arrived with a board asking if the bank should settle a matched-pair study for community-development lender. That is a Fair Lending Redlining and HMDA Data decision on a redlining pattern exists in a mortgage company after a pricing-regression spike.

Decision

Community-development lender in a mortgage company after a pricing-regression spike 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 board asking if the bank should settle a matched-pair study.

Hypotheses to test

• Authorize Remove access or reverse the item now; geographic application and origination heat map already has the discriminator after a board asking if the bank should settle a matched-pair study.
• Keep Temporary compensating control in force until geographic application and origination heat map is completed after a board asking if the bank should settle a matched-pair study for community-development lender.
• Treat geographic application and origination heat map as Approve a documented exception because both readings appear after a board asking if the bank should settle a matched-pair study.
• Refuse a Fair Lending close: community-development lender does not have the page a redlining pattern exists turns on in geographic application and origination heat map.

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 board asking if the bank should settle a matched-pair study.
• For this Fair Lending Redlining and HMDA Data file, read geographic application and origination heat map against a board asking if the bank should settle a matched-pair study and write the one fact that would move a redlining pattern exists for community-development lender.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (geographic application and origination heat map after a board asking if the bank should settle a matched-pair study). Lead with the Fair Lending option geographic application and origination heat map can support after a board asking if the bank should settle a matched-pair study, then the two facts that force it, then the Monday action for community-development lender in a mortgage company after a pricing-regression spike.