Assess whether a redlining pattern exists after controls (f62e92)

Situation

A redlining pattern exists sits with second-review underwriter because a marketing mailer that skipped majority-minority tracts hit a lender expanding into majority-minority census tracts. Evidence is adverse-action notice principal-reason sample; write the Fair Lending CRA and Special-Purpose Programs option that extract can carry.

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 adverse-action notice principal-reason sample after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Adverse-action notice principal-reason sample 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.
• Adverse-action notice principal-reason sample 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 CRA and Special-Purpose Programs extract.
• Approve a documented exception is still live in adverse-action notice principal-reason sample for second-review underwriter in a lender expanding into majority-minority census tracts.
• Adverse-action notice principal-reason sample is missing the fact second-review underwriter needs after a marketing mailer that skipped majority-minority tracts; stop this Fair Lending close.

Analysis required

• Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts.
• Flag any disparate-impact table second-review underwriter cannot explain from adverse-action notice principal-reason sample.
• Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend.
• For this Fair Lending CRA and Special-Purpose Programs file, read adverse-action notice principal-reason sample against a marketing mailer that skipped majority-minority tracts and write the one fact that would move a redlining pattern exists for second-review underwriter.

Recommendation