Whether a redlining pattern exists after controls from appraisal-gap outcomes

Situation

In a lender expanding into majority-minority census tracts, appraisal-gap outcomes in majority-minority tracts is the evidence after an exception rate twice as high for one group after credit controls. Adverse-action notice operations lead has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data close using appraisal-gap outcomes in majority-minority tracts.

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 an exception rate twice as high for one group after credit controls.

Hypotheses to test

• Authorize Remove access or reverse the item now; appraisal-gap outcomes in majority-minority tracts already has the discriminator after an exception rate twice as high for one group after credit controls.
• Keep Temporary compensating control in force until appraisal-gap outcomes in majority-minority tracts is completed after an exception rate twice as high for one group after credit controls for adverse-action notice operations lead.
• Treat appraisal-gap outcomes in majority-minority tracts as Approve a documented exception because both readings appear after an exception rate twice as high for one group after credit controls.
• Refuse a Fair Lending close: adverse-action notice operations lead does not have the page a redlining pattern exists turns on in appraisal-gap outcomes in majority-minority tracts.

Analysis required

• Check HMDA coding and underwriting policy against a redlining pattern exists.
• Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls.
• Flag any disparate-impact table adverse-action notice operations lead cannot explain from appraisal-gap outcomes in majority-minority tracts.
• For this Fair Lending Redlining and HMDA Data file, read appraisal-gap outcomes in majority-minority tracts against an exception rate twice as high for one group after credit controls and write the one fact that would move a redlining pattern exists for adverse-action notice operations lead.