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

Situation

Appraisal-gap outcomes in majority-minority tracts arrived with a marketing mailer that skipped majority-minority tracts for community-development lender. That is a Fair Lending Examination and Notices decision on line assignments have a in a manufactured-housing lender with dealer-originated files.

Decision

Community-development lender in a manufactured-housing lender with dealer-originated files 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 marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Appraisal-gap outcomes in majority-minority tracts reads as Remove access or reverse the item once a marketing mailer that skipped majority-minority tracts is lined up to the same Fair Lending population.
• Appraisal-gap outcomes in majority-minority tracts is closer to Temporary compensating control after a marketing mailer that skipped majority-minority tracts; Remove access or reverse the item would over-claim this Examination and Notices extract.
• Approve a documented exception is still live in appraisal-gap outcomes in majority-minority tracts for community-development lender in a manufactured-housing lender with dealer-originated files.
• Appraisal-gap outcomes in majority-minority tracts is missing the fact community-development lender needs after a marketing mailer that skipped majority-minority tracts; stop this Fair Lending close.

Analysis required

• Flag any disparate-impact table community-development lender cannot explain from appraisal-gap outcomes in majority-minority tracts.
• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts.
• For this Fair Lending Examination and Notices file, read appraisal-gap outcomes in majority-minority tracts against a marketing mailer that skipped majority-minority tracts and write the one fact that would move line assignments have a for community-development lender.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (appraisal-gap outcomes in majority-minority tracts after a marketing mailer that skipped majority-minority tracts). If appraisal-gap outcomes in majority-minority tracts cannot force a Fair Lending label under Examination and Notices, stop. Do not invent pages a manufactured-housing lender with dealer-originated files does not have.