Assess whether a redlining pattern exists after controls after a board asking

Situation

CRA strategist in an institution preparing for a redlining exam has one working extract — underwriting exception log by branch — after a board asking if the bank should settle a matched-pair study. If underwriting exception log by branch cannot support a redlining pattern exists, the honest Fair Lending output is hold.

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 underwriting exception log by branch after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• CRA strategist can defend Remove access or reverse the item from underwriting exception log by branch after a board asking if the bank should settle a matched-pair study in a Fair Lending challenge.
• CRA strategist cannot defend Remove access or reverse the item from underwriting exception log by branch; Temporary compensating control is what the extract actually supports after a board asking if the bank should settle a matched-pair study.
• A board asking if the bank should settle a matched-pair study never reached the population in underwriting exception log by branch — reopen intake, do not close a redlining pattern exists.
• Two facts in underwriting exception log by branch after a board asking if the bank should settle a matched-pair study conflict for CRA strategist; hold this Redlining and HMDA Data file.

Analysis required

• Check HMDA coding and underwriting policy against a redlining pattern exists.
• Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study.
• Flag any disparate-impact table CRA strategist cannot explain from underwriting exception log by branch.
• For this Fair Lending Redlining and HMDA Data file, read underwriting exception log by branch against a board asking if the bank should settle a matched-pair study 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 (underwriting exception log by branch after a board asking if the bank should settle a matched-pair study). Lead with the Fair Lending option underwriting exception log by branch can support after a board asking if the bank should settle a matched-pair study, then the two facts that force it, then the Monday action for CRA strategist in an institution preparing for a redlining exam.