Assess whether a redlining pattern exists after controls (9d9fe2)

Situation

A redlining pattern exists sits with fair-lending officer because a SPCP that originated almost no loans to the intended class hit an institution preparing for a redlining exam. Evidence is appraisal-gap outcomes in majority-minority tracts; write the Fair Lending Examination and Notices option that extract can carry.

Decision

Fair-lending officer 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 SPCP that originated almost no loans to the intended class.

Hypotheses to test

• Authorize Remove access or reverse the item now; appraisal-gap outcomes in majority-minority tracts already has the discriminator after a SPCP that originated almost no loans to the intended class.
• Keep Temporary compensating control in force until appraisal-gap outcomes in majority-minority tracts is completed after a SPCP that originated almost no loans to the intended class for fair-lending officer.
• Treat appraisal-gap outcomes in majority-minority tracts as Approve a documented exception because both readings appear after a SPCP that originated almost no loans to the intended class.
• Refuse a Fair Lending close: fair-lending officer does not have the page a redlining pattern exists turns on in appraisal-gap outcomes in majority-minority tracts.

Analysis required

• Flag any disparate-impact table fair-lending officer cannot explain from appraisal-gap outcomes in majority-minority tracts.
• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts.
• For this Fair Lending Examination and Notices file, read appraisal-gap outcomes in majority-minority tracts against a SPCP that originated almost no loans to the intended class and write the one fact that would move a redlining pattern exists for fair-lending officer.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (appraisal-gap outcomes in majority-minority tracts after a SPCP that originated almost no loans to the intended class). The follow-on Examination and Notices action is what fair-lending officer does next: implement the option, assign an owner, and log the missing fact.