Exam-response coordinator must resolve whether a redlining pattern exists

Situation

The desk packet is manufactured-housing dealer overlay notes after a CRA PE that called the assessment area too narrow. Exam-response coordinator 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 Pricing and Credit Limits file.

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 manufactured-housing dealer overlay notes after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• Manufactured-housing dealer overlay notes reads as Remove access or reverse the item once a CRA PE that called the assessment area too narrow is lined up to the same Fair Lending population.
• Manufactured-housing dealer overlay notes is closer to Temporary compensating control after a CRA PE that called the assessment area too narrow; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract.
• Approve a documented exception is still live in manufactured-housing dealer overlay notes for exam-response coordinator in an institution preparing for a redlining exam.
• Manufactured-housing dealer overlay notes is missing the fact exam-response coordinator needs after a CRA PE that called the assessment area too narrow; stop this Fair Lending close.

Analysis required

• Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow.
• Flag any disparate-impact table exam-response coordinator cannot explain from manufactured-housing dealer overlay notes.
• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• For this Fair Lending Pricing and Credit Limits file, read manufactured-housing dealer overlay notes against a CRA PE that called the assessment area too narrow 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 (manufactured-housing dealer overlay notes after a CRA PE that called the assessment area too narrow). If manufactured-housing dealer overlay notes 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.