Assess whether a redlining pattern exists after controls (c30899)

Situation

The desk packet is HMDA LAR validity and quality edits after a DOJ or CFPB monitor request for pricing files. CRA strategist in an institution preparing for a redlining exam has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data file.

Decision

CRA strategist 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 HMDA LAR validity and quality edits after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• Authorize Remove access or reverse the item now; HMDA LAR validity and quality edits already has the discriminator after a DOJ or CFPB monitor request for pricing files.
• Keep Temporary compensating control in force until HMDA LAR validity and quality edits is completed after a DOJ or CFPB monitor request for pricing files for CRA strategist.
• Treat HMDA LAR validity and quality edits as Approve a documented exception because both readings appear after a DOJ or CFPB monitor request for pricing files.
• Refuse a Fair Lending close: CRA strategist does not have the page a redlining pattern exists turns on in HMDA LAR validity and quality edits.

Analysis required

• Flag any disparate-impact table CRA strategist cannot explain from HMDA LAR validity and quality edits.
• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• Match the adverse-action language to the facts in HMDA LAR validity and quality edits.
• For this Fair Lending Redlining and HMDA Data file, read HMDA LAR validity and quality edits against a DOJ or CFPB monitor request for pricing files 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 / Redlining and HMDA Data packet (HMDA LAR validity and quality edits after a DOJ or CFPB monitor request for pricing files). The follow-on Redlining and HMDA Data action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.