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

SITUATION A board asking if the bank should settle a matched-pair study put appraisal-gap outcomes in majority-minority tracts in front of CRA strategist in an institution preparing for a redlining exam. 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 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 appraisal-gap outcomes in majority-minority tracts after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; appraisal-gap outcomes in majority-minority tracts already has the discriminator after a board asking if the bank should settle a matched-pair study. 2. Keep Temporary compensating control in force until appraisal-gap outcomes in majority-minority tracts is completed after a board asking if the bank should settle a matched-pair study for CRA strategist. 3. Treat appraisal-gap outcomes in majority-minority tracts as Approve a documented exception because both readings appear after a board asking if the bank should settle a matched-pair study. 4. Refuse a Fair Lending close: CRA strategist does not have the decision line assignments have a turns on in appraisal-gap outcomes in majority-minority tracts.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern an institution preparing for a redlining exam must defend. 2. Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts. 3. Check HMDA coding and underwriting policy against line assignments have a. 4. For this Fair Lending Redlining and HMDA Data file, read appraisal-gap outcomes in majority-minority tracts against a board asking if the bank should settle a matched-pair study and write the one fact that would move line assignments have a 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 (appraisal-gap outcomes in majority-minority tracts after a board asking if the bank should settle a matched-pair study). Lead with the Fair Lending option appraisal-gap outcomes in majority-minority tracts 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.