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

SITUATION After a community complaint about appraisal gaps, mortgage pricing residual by prohibited-basis group is what second-review underwriter can touch in a lender expanding into majority-minority census tracts. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this CRA and Special-Purpose Programs file.

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. A community complaint about appraisal gaps is noise around an already-controlled CRA and Special-Purpose Programs process in a lender expanding into majority-minority census tracts, given mortgage pricing residual by prohibited-basis group. 2. A community complaint about appraisal gaps is the event in mortgage pricing residual by prohibited-basis group that forces Remove access or reverse the item for second-review underwriter under Fair Lending. 3. Mortgage pricing residual by prohibited-basis group shows a one-file miss after a community complaint about appraisal gaps, not a CRA and Special-Purpose Programs program failure. 4. Mortgage pricing residual by prohibited-basis group cannot decide line assignments have a yet after a community complaint about appraisal gaps; hold is the only Fair Lending close a lender expanding into majority-minority census tracts can defend.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group. 2. Check HMDA coding and underwriting policy against line assignments have a. 3. 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. 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 line assignments have a 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). Lead with the Fair Lending option mortgage pricing residual by prohibited-basis group can support after a community complaint about appraisal gaps, then the two facts that force it, then the Monday action for second-review underwriter in a lender expanding into majority-minority census tracts.