Assess whether a redlining pattern exists after controls from small-business

Situation

Pricing and Credit Limits work in an institution preparing for a redlining exam now turns on a redlining pattern exists because a DOJ or CFPB monitor request for pricing files put small-business decline comparative file set in play. Exam-response coordinator should say what small-business decline comparative file set proves.

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 small-business decline comparative file set after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• Small-business decline comparative file set reads as Remove access or reverse the item once a DOJ or CFPB monitor request for pricing files is lined up to the same Fair Lending population.
• Small-business decline comparative file set is closer to Temporary compensating control after a DOJ or CFPB monitor request for pricing files; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract.
• Approve a documented exception is still live in small-business decline comparative file set for exam-response coordinator in an institution preparing for a redlining exam.
• Small-business decline comparative file set is missing the fact exam-response coordinator needs after a DOJ or CFPB monitor request for pricing files; stop this Fair Lending close.

Analysis required

• Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files.
• Flag any disparate-impact table exam-response coordinator cannot explain from small-business decline comparative file set.
• 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 small-business decline comparative file set against a DOJ or CFPB monitor request for pricing files 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 (small-business decline comparative file set after a DOJ or CFPB monitor request for pricing files). If small-business decline comparative file set 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.