Assess whether comparative files show second-review bias (c27df7)

Situation

In a bank with thin HMDA LAR quality, appraisal-gap outcomes in majority-minority tracts is the evidence after a community complaint about appraisal gaps. Exam-response coordinator has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data close using appraisal-gap outcomes in majority-minority tracts.

Decision

Exam-response coordinator in a bank with thin HMDA LAR quality 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

• 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.
• Keep Temporary compensating control in force until appraisal-gap outcomes in majority-minority tracts is completed after a community complaint about appraisal gaps for exam-response coordinator.
• Treat appraisal-gap outcomes in majority-minority tracts as Approve a documented exception because both readings appear after a community complaint about appraisal gaps.
• Refuse a Fair Lending close: exam-response coordinator does not have the page comparative files show second-review turns on in appraisal-gap outcomes in majority-minority tracts.

Analysis required

• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts.
• Check HMDA coding and underwriting policy against comparative files show second-review.
• For this Fair Lending Redlining and HMDA Data file, read appraisal-gap outcomes in majority-minority tracts against a community complaint about appraisal gaps and write the one fact that would move comparative files show second-review for exam-response coordinator.

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 community complaint about appraisal gaps). The follow-on Redlining and HMDA Data action is what exam-response coordinator does next: implement the option, assign an owner, and log the missing fact.