Assess whether a redlining pattern exists after controls (a8a83c)

Situation

CRA and Special-Purpose Programs work in a lender expanding into majority-minority census tracts now turns on a redlining pattern exists because a branch that stopped taking applications in one ZIP put underwriting exception log by branch in play. CRA and Special-Purpose Programs work in a lender expanding into majority-minority census tracts now turns on a redlining pattern exists because a branch that stopped taking applications in one ZIP put underwriting exception log by branch in play; second-review underwriter should say what underwriting exception log by branch proves for Fair Lending.

Decision

Second-review underwriter in a lender expanding into majority-minority census tracts must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using underwriting exception log by branch after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• A branch that stopped taking applications in one ZIP is noise around an already-controlled CRA and Special-Purpose Programs process in a lender expanding into majority-minority census tracts, given underwriting exception log by branch.
• A branch that stopped taking applications in one ZIP is the event in underwriting exception log by branch that forces Remove access or reverse the item for second-review underwriter under Fair Lending.
• Underwriting exception log by branch shows a one-file miss after a branch that stopped taking applications in one ZIP, not a CRA and Special-Purpose Programs program failure.
• Underwriting exception log by branch cannot decide a redlining pattern exists yet after a branch that stopped taking applications in one ZIP; hold is the only Fair Lending close a lender expanding into majority-minority census tracts can defend.

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 branch that stopped taking applications in one ZIP.
• Flag any disparate-impact table second-review underwriter cannot explain from underwriting exception log by branch.
• For this Fair Lending CRA and Special-Purpose Programs file, read underwriting exception log by branch against a branch that stopped taking applications in one ZIP and write the one fact that would move a redlining pattern exists for second-review underwriter.