Assess whether the exam response should concede a finding (0b49c0)

SITUATION CRA and Special-Purpose Programs work in a lender expanding into majority-minority census tracts now turns on the exam response should because a community complaint about appraisal gaps put mortgage pricing residual by prohibited-basis group in play. Second-review underwriter should say what mortgage pricing residual by prohibited-basis group proves.

DECISION Second-review underwriter in a lender expanding into majority-minority census tracts 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 community complaint about appraisal gaps.

HYPOTHESES TO TEST 1. Mortgage pricing residual by prohibited-basis group reads as Remove access or reverse the item once a community complaint about appraisal gaps is lined up to the same Fair Lending population. 2. Mortgage pricing residual by prohibited-basis group is closer to Temporary compensating control after a community complaint about appraisal gaps; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract. 3. Approve a documented exception is still live in mortgage pricing residual by prohibited-basis group for second-review underwriter in a lender expanding into majority-minority census tracts. 4. Mortgage pricing residual by prohibited-basis group is missing the fact second-review underwriter needs after a community complaint about appraisal gaps; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps. 2. Flag any disparate-impact table second-review underwriter cannot explain from mortgage pricing residual by prohibited-basis group. 3. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 4. For this Fair Lending CRA and Special-Purpose Programs file, read mortgage pricing residual by prohibited-basis group against a community complaint about appraisal gaps and write the one fact that would move the exam response should for second-review underwriter.

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 community complaint about appraisal gaps). 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 community complaint about appraisal gaps cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, second-review underwriter must do not infer a control or scheme beyond the transaction and entitlement evidence.