Assess whether a redlining pattern exists after controls (c442cb)

Situation

A bank with thin HMDA LAR quality cannot treat an underwriter chat that used coded language as color commentary on geographic application and origination heat map. Fair-lending officer must close a redlining pattern exists from that extract under Fair Lending / CRA and Special-Purpose Programs.

Decision

Fair-lending officer in a bank with thin HMDA LAR quality must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using geographic application and origination heat map after an underwriter chat that used coded language.

Hypotheses to test

• An underwriter chat that used coded language is noise around an already-controlled CRA and Special-Purpose Programs process in a bank with thin HMDA LAR quality, given geographic application and origination heat map.
• An underwriter chat that used coded language is the event in geographic application and origination heat map that forces Remove access or reverse the item for fair-lending officer under Fair Lending.
• Geographic application and origination heat map shows a one-file miss after an underwriter chat that used coded language, not a CRA and Special-Purpose Programs program failure.
• Geographic application and origination heat map cannot decide a redlining pattern exists yet after an underwriter chat that used coded language; hold is the only Fair Lending close a bank with thin HMDA LAR quality can defend.

Analysis required

• 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 an underwriter chat that used coded language.
• Flag any disparate-impact table fair-lending officer cannot explain from geographic application and origination heat map.
• For this Fair Lending CRA and Special-Purpose Programs file, read geographic application and origination heat map against an underwriter chat that used coded language and write the one fact that would move a redlining pattern exists for fair-lending officer.

Recommendation

Treat this reading of geographic application and origination heat map as the gate for a redlining pattern exists: Check HMDA coding and underwriting policy against a redlining pattern exists.. If geographic application and origination heat map after an underwriter chat that used coded language confirms that reading, fair-lending officer takes Remove access or reverse the item in a bank with thin HMDA LAR quality. If geographic application and origination heat map contradicts it, take Temporary compensating control.