Assess whether notices match the actual decisioning reasons (1b7f0c)

SITUATION A manufactured-housing lender with dealer-originated files cannot treat a community complaint about appraisal gaps as incidental context on appraisal-gap outcomes in majority-minority tracts. Community-development lender must close notices match the actual from that extract under Fair Lending / Examination and Notices.

DECISION Community-development lender in a manufactured-housing lender with dealer-originated files 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 community complaint about appraisal gaps.

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 community complaint about appraisal gaps. 2. Keep Temporary compensating control in force until appraisal-gap outcomes in majority-minority tracts is completed after a community complaint about appraisal gaps for community-development lender. 3. Treat appraisal-gap outcomes in majority-minority tracts as Approve a documented exception because both readings appear after a community complaint about appraisal gaps. 4. Refuse a Fair Lending close: community-development lender does not have the decision notices match the actual turns on in appraisal-gap outcomes in majority-minority tracts.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts. 2. Check HMDA coding and underwriting policy against notices match the actual. 3. Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps. 4. For this Fair Lending Examination and Notices file, read appraisal-gap outcomes in majority-minority tracts against a community complaint about appraisal gaps and write the one fact that would move notices match the actual for community-development lender.

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 community complaint about appraisal gaps). Lead with the Fair Lending option appraisal-gap outcomes in majority-minority tracts can support after a community complaint about appraisal gaps, then the two facts that force it, then the Monday action for community-development lender in a manufactured-housing lender with dealer-originated files.

COMMAND RETURNS - Bottom-line Fair Lending option on notices match the actual, then the evidence in appraisal-gap outcomes in majority-minority tracts, then the action for community-development lender - Hypothesis scorecard against appraisal-gap outcomes in majority-minority tracts: supported / rejected / untestable - Regulatory or exam hook Examination and Notices would cite - Examination and Notices finding in appraisal-gap outcomes in majority-minority tracts that a second reviewer can re-perform