Assess whether comparative files show second-review bias from appraisal-gap

SITUATION The working file is appraisal-gap outcomes in majority-minority tracts after an underwriter chat that used coded language. Community-development lender in a bank with thin HMDA LAR quality has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits file.

DECISION Community-development lender 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 an underwriter chat that used coded language.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; appraisal-gap outcomes in majority-minority tracts already has the discriminator after an underwriter chat that used coded language. 2. Keep Temporary compensating control in force until appraisal-gap outcomes in majority-minority tracts is completed after an underwriter chat that used coded language for community-development lender. 3. Treat appraisal-gap outcomes in majority-minority tracts as Approve a documented exception because both readings appear after an underwriter chat that used coded language. 4. Refuse a Fair Lending close: community-development lender does not have the decision comparative files show second-review turns on in appraisal-gap outcomes in majority-minority tracts.

ANALYSIS REQUIRED 1. Flag any disparate-impact table community-development lender cannot explain from appraisal-gap outcomes in majority-minority tracts. 2. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 3. Match the adverse-action language to the facts in 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 an underwriter chat that used coded language and write the one fact that would move comparative files show second-review for community-development lender.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (appraisal-gap outcomes in majority-minority tracts after an underwriter chat that used coded language). The follow-on Pricing and Credit Limits action is what community-development lender does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on comparative files show second-review, then the evidence in appraisal-gap outcomes in majority-minority tracts, then the action for community-development lender - Hypothesis scorecard against appraisal-gap outcomes in majority-minority tracts: supported / rejected / untestable - Regulatory or exam hook Pricing and Credit Limits would cite - Pricing and Credit Limits finding in appraisal-gap outcomes in majority-minority tracts that a second reviewer can re-perform