Assess whether a redlining pattern exists after controls after a branch that

Situation

Exam-response coordinator in a bank with thin HMDA LAR quality has one working extract — SPCP written plan versus actual originations — after a branch that stopped taking applications in one ZIP. If SPCP written plan versus actual originations cannot support a redlining pattern exists, the honest Fair Lending output is hold.

Decision

Exam-response coordinator 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 SPCP written plan versus actual originations after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• SPCP written plan versus actual originations reads as Remove access or reverse the item once a branch that stopped taking applications in one ZIP is lined up to the same Fair Lending population.
• SPCP written plan versus actual originations is closer to Temporary compensating control after a branch that stopped taking applications in one ZIP; Remove access or reverse the item would over-claim this Redlining and HMDA Data extract.
• Approve a documented exception is still live in SPCP written plan versus actual originations for exam-response coordinator in a bank with thin HMDA LAR quality.
• SPCP written plan versus actual originations is missing the fact exam-response coordinator needs after a branch that stopped taking applications in one ZIP; stop this Fair Lending close.

Analysis required

• Check HMDA coding and underwriting policy against a redlining pattern exists.
• Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP.
• Flag any disparate-impact table exam-response coordinator cannot explain from SPCP written plan versus actual originations.
• For this Fair Lending Redlining and HMDA Data file, read SPCP written plan versus actual originations against a branch that stopped taking applications in one ZIP 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 / Redlining and HMDA Data packet (SPCP written plan versus actual originations after a branch that stopped taking applications in one ZIP). If SPCP written plan versus actual originations cannot force a Fair Lending label under Redlining and HMDA Data, stop. If SPCP written plan versus actual originations after a branch that stopped taking applications in one ZIP cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Redlining and HMDA Data close, exam-response coordinator must do not infer a control or scheme beyond the transaction and entitlement evidence.