Assess whether a redlining pattern exists after controls (b8b0c3)

Situation

After a community complaint about appraisal gaps, model-reason-code mapping that does not match notices is what CRA strategist can touch in a bank with thin HMDA LAR quality. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Examination and Notices file.

Decision

CRA strategist 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 model-reason-code mapping that does not match notices after a community complaint about appraisal gaps.

Hypotheses to test

• A community complaint about appraisal gaps is noise around an already-controlled Examination and Notices process in a bank with thin HMDA LAR quality, given model-reason-code mapping that does not match notices.
• A community complaint about appraisal gaps is the event in model-reason-code mapping that does not match notices that forces Remove access or reverse the item for CRA strategist under Fair Lending.
• Model-reason-code mapping that does not match notices shows a one-file miss after a community complaint about appraisal gaps, not a Examination and Notices program failure.
• Model-reason-code mapping that does not match notices cannot decide a redlining pattern exists yet after a community complaint about appraisal gaps; hold is the only Fair Lending close a bank with thin HMDA LAR quality can defend.

Analysis required

• Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps.
• Flag any disparate-impact table CRA strategist cannot explain from model-reason-code mapping that does not match notices.
• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• For this Fair Lending Examination and Notices file, read model-reason-code mapping that does not match notices against a community complaint about appraisal gaps 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 / Examination and Notices packet (model-reason-code mapping that does not match notices after a community complaint about appraisal gaps). Lead with the Fair Lending option model-reason-code mapping that does not match notices can support after a community complaint about appraisal gaps, then the two facts that force it, then the Monday action for CRA strategist in a bank with thin HMDA LAR quality.