The Exam Response Should Concede a Finding — Fair Lending

Situation

In an institution preparing for a redlining exam, appraisal-gap outcomes in majority-minority tracts is the evidence after a notice that cites 'other' as the principal reason 40% of the time. Exam-response coordinator has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits close using appraisal-gap outcomes in majority-minority tracts.

Decision

Exam-response coordinator in an institution preparing for a redlining exam 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

• The population in appraisal-gap outcomes in majority-minority tracts is the one a notice that cites 'other' as the principal reason 40% of the time named, so Remove access or reverse the item follows for this Pricing and Credit Limits file.
• The population in appraisal-gap outcomes in majority-minority tracts is adjacent only to a notice that cites 'other' as the principal reason 40% of the time; Temporary compensating control is the honest Fair Lending call.
• An institution preparing for a redlining exam already contained a notice that cites 'other' as the principal reason 40% of the time before appraisal-gap outcomes in majority-minority tracts arrived; no new Pricing and Credit Limits path.
• Provenance on appraisal-gap outcomes in majority-minority tracts after a notice that cites 'other' as the principal reason 40% of the time is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• 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.
• Flag any disparate-impact table exam-response coordinator cannot explain from appraisal-gap outcomes in majority-minority tracts.
• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• For this Fair Lending Pricing and Credit Limits 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 the exam response should for exam-response coordinator.