Assess whether a redlining pattern exists after controls (c3e84f)

Situation

Mortgage pricing residual by prohibited-basis group arrived with a marketing mailer that skipped majority-minority tracts for HMDA data-quality manager. That is a Fair Lending CRA and Special-Purpose Programs decision on a redlining pattern exists in a credit union rolling out a special-purpose credit program.

Decision

HMDA data-quality manager 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 mortgage pricing residual by prohibited-basis group after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Mortgage pricing residual by prohibited-basis group reads as Remove access or reverse the item once a marketing mailer that skipped majority-minority tracts is lined up to the same Fair Lending population.
• Mortgage pricing residual by prohibited-basis group is closer to Temporary compensating control after a marketing mailer that skipped majority-minority tracts; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract.
• Approve a documented exception is still live in mortgage pricing residual by prohibited-basis group for HMDA data-quality manager in a credit union rolling out a special-purpose credit program.
• Mortgage pricing residual by prohibited-basis group is missing the fact HMDA data-quality manager needs after a marketing mailer that skipped majority-minority tracts; stop this Fair Lending close.

Analysis required

• Flag any disparate-impact table HMDA data-quality manager cannot explain from mortgage pricing residual by prohibited-basis group.
• Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend.
• Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group.
• For this Fair Lending CRA and Special-Purpose Programs file, read mortgage pricing residual by prohibited-basis group against a marketing mailer that skipped majority-minority tracts and write the one fact that would move a redlining pattern exists for HMDA data-quality manager.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (mortgage pricing residual by prohibited-basis group after a marketing mailer that skipped majority-minority tracts). If mortgage pricing residual by prohibited-basis group cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If mortgage pricing residual by prohibited-basis group after a marketing mailer that skipped majority-minority tracts cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, HMDA data-quality manager must do not infer a control or scheme beyond the transaction and entitlement evidence.