Assess whether comparative files show second-review bias after a SPCP that

Situation

A SPCP that originated almost no loans to the intended class 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 comparative files show second-review 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 SPCP that originated almost no loans to the intended class.

Hypotheses to test

• A SPCP that originated almost no loans to the intended class is noise around an already-controlled Redlining and HMDA Data process in an institution preparing for a redlining exam, given appraisal-gap outcomes in majority-minority tracts.
• A SPCP that originated almost no loans to the intended class is the event in appraisal-gap outcomes in majority-minority tracts that forces Remove access or reverse the item for CRA strategist under Fair Lending.
• Appraisal-gap outcomes in majority-minority tracts shows a one-file miss after a SPCP that originated almost no loans to the intended class, not a Redlining and HMDA Data program failure.
• Appraisal-gap outcomes in majority-minority tracts cannot decide comparative files show second-review yet after a SPCP that originated almost no loans to the intended class; hold is the only Fair Lending close an institution preparing for a redlining exam can defend.

Analysis required

• Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class.
• Flag any disparate-impact table CRA strategist 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.
• For this Fair Lending Redlining and HMDA Data 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 comparative files show second-review for CRA strategist.