Assess whether line assignments have a disparate impact the bank will defend

SITUATION A vendor score change with no disparate-impact test put appraisal-gap outcomes in majority-minority tracts in front of adverse-action notice operations lead in a lender expanding into majority-minority census tracts. This Fair Lending / Redlining and HMDA Data close is line assignments have a from appraisal-gap outcomes in majority-minority tracts, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

DECISION Adverse-action notice operations lead 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 appraisal-gap outcomes in majority-minority tracts after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. The population in appraisal-gap outcomes in majority-minority tracts is the one a vendor score change with no disparate-impact test named, so Remove access or reverse the item follows for this Redlining and HMDA Data file. 2. The population in appraisal-gap outcomes in majority-minority tracts is adjacent only to a vendor score change with no disparate-impact test; Temporary compensating control is the honest Fair Lending call. 3. A lender expanding into majority-minority census tracts already contained a vendor score change with no disparate-impact test before appraisal-gap outcomes in majority-minority tracts arrived; no new Redlining and HMDA Data path. 4. Provenance on appraisal-gap outcomes in majority-minority tracts after a vendor score change with no disparate-impact test is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against line assignments have a. 2. Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test. 3. Flag any disparate-impact table adverse-action notice operations lead cannot explain from appraisal-gap outcomes in majority-minority tracts. 4. For this Fair Lending Redlining and HMDA Data file, read appraisal-gap outcomes in majority-minority tracts against a vendor score change with no disparate-impact test and write the one fact that would move line assignments have a for adverse-action notice operations lead.

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 (appraisal-gap outcomes in majority-minority tracts after a vendor score change with no disparate-impact test). Lead with the Fair Lending option appraisal-gap outcomes in majority-minority tracts can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for adverse-action notice operations lead in a lender expanding into majority-minority census tracts.