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

SITUATION CRA strategist in a manufactured-housing lender with dealer-originated files has one working extract — appraisal-gap outcomes in majority-minority tracts — after a community complaint about appraisal gaps. If appraisal-gap outcomes in majority-minority tracts cannot support line assignments have a, the only defensible Fair Lending output is hold.

DECISION CRA strategist 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. CRA strategist can defend Remove access or reverse the item from appraisal-gap outcomes in majority-minority tracts after a community complaint about appraisal gaps in a Fair Lending challenge. 2. CRA strategist cannot defend Remove access or reverse the item from appraisal-gap outcomes in majority-minority tracts; Temporary compensating control is what the extract actually supports after a community complaint about appraisal gaps. 3. A community complaint about appraisal gaps never reached the population in appraisal-gap outcomes in majority-minority tracts — reopen intake, do not close line assignments have a. 4. Two facts in appraisal-gap outcomes in majority-minority tracts after a community complaint about appraisal gaps conflict for CRA strategist; hold this Pricing and Credit Limits file.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against line assignments have a. 2. 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. 3. Flag any disparate-impact table CRA strategist cannot explain from appraisal-gap outcomes in majority-minority tracts. 4. For this Fair Lending Pricing and Credit Limits file, read appraisal-gap outcomes in majority-minority tracts against a community complaint about appraisal gaps and write the one fact that would move line assignments have a for CRA strategist.

RECOMMENDATION Release Remove access or reverse the item for this Fair Lending Pricing and Credit Limits file only when appraisal-gap outcomes in majority-minority tracts after a community complaint about appraisal gaps names the fact line assignments have a requires. CRA strategist in a manufactured-housing lender with dealer-originated files should withhold Remove access or reverse the item while that fact is still a hole in appraisal-gap outcomes in majority-minority tracts.

COMMAND RETURNS - Bottom-line Fair Lending option on line assignments have a, then the evidence in appraisal-gap outcomes in majority-minority tracts, then the action for CRA strategist - Hypothesis scorecard against appraisal-gap outcomes in majority-minority tracts: supported / rejected / untestable - Pricing and Credit Limits finding in appraisal-gap outcomes in majority-minority tracts that a second reviewer can re-perform - Missing page in appraisal-gap outcomes in majority-minority tracts after a community complaint about appraisal gaps, if any