Assess whether a redlining pattern exists after controls (034d11)

Situation

After a notice that cites 'other' as the principal reason 40% of the time, appraisal-gap outcomes in majority-minority tracts is what model-risk partner for credit scoring can touch in a credit union rolling out a special-purpose credit program. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Redlining and HMDA Data file.

Decision

Model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program 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 notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• Model-risk partner for credit scoring can defend Remove access or reverse the item from appraisal-gap outcomes in majority-minority tracts after a notice that cites 'other' as the principal reason 40% of the time in a Fair Lending challenge.
• Model-risk partner for credit scoring 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 notice that cites 'other' as the principal reason 40% of the time.
• A notice that cites 'other' as the principal reason 40% of the time never reached the population in appraisal-gap outcomes in majority-minority tracts — reopen intake, do not close a redlining pattern exists.
• Two facts in appraisal-gap outcomes in majority-minority tracts after a notice that cites 'other' as the principal reason 40% of the time conflict for model-risk partner for credit scoring; hold this Redlining and HMDA Data file.

Analysis required

• Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts.
• Check HMDA coding and underwriting policy against a redlining pattern exists.
• Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time.
• For this Fair Lending Redlining and HMDA Data file, read appraisal-gap outcomes in majority-minority tracts against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move a redlining pattern exists for model-risk partner for credit scoring.