Assess whether line assignments have a disparate impact the bank will defend

SITUATION The Redlining and HMDA Data working file is appraisal-gap outcomes in majority-minority tracts after a CRA PE that called the assessment area too narrow. CRA strategist in an institution preparing for a redlining exam must name Remove access or reverse the item or Temporary compensating control for this Fair Lending file. CRA strategist in an institution preparing for a redlining exam has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data file.

DECISION CRA strategist 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 CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. A CRA PE that called the assessment area too narrow is noise around an already-controlled Redlining and HMDA Data process in an institution preparing for a redlining exam, given appraisal-gap outcomes in majority-minority tracts. 2. A CRA PE that called the assessment area too narrow is the event in appraisal-gap outcomes in majority-minority tracts that forces Remove access or reverse the item for CRA strategist under Fair Lending. 3. Appraisal-gap outcomes in majority-minority tracts shows a one-file miss after a CRA PE that called the assessment area too narrow, not a Redlining and HMDA Data program failure. 4. Appraisal-gap outcomes in majority-minority tracts cannot decide line assignments have a yet after a CRA PE that called the assessment area too narrow; hold is the only Fair Lending close an institution preparing for a redlining exam can defend.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern an institution preparing for a redlining exam must defend. 2. Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts. 3. Check HMDA coding and underwriting policy against line assignments have a. 4. For this Fair Lending Redlining and HMDA Data file, read appraisal-gap outcomes in majority-minority tracts against a CRA PE that called the assessment area too narrow and write the one fact that would move line assignments have a for CRA strategist.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (appraisal-gap outcomes in majority-minority tracts after a CRA PE that called the assessment area too narrow). The follow-on Redlining and HMDA Data action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.