Assess whether a redlining pattern exists after controls (e21a5d)

Situation

A redlining pattern exists sits with exam-response coordinator because a community complaint about appraisal gaps hit a manufactured-housing lender with dealer-originated files. Evidence is HMDA LAR validity and quality edits; write the Fair Lending CRA and Special-Purpose Programs option that extract can carry.

Decision

Exam-response coordinator 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 HMDA LAR validity and quality edits after a community complaint about appraisal gaps.

Hypotheses to test

• The population in HMDA LAR validity and quality edits is the one a community complaint about appraisal gaps named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file.
• The population in HMDA LAR validity and quality edits is adjacent only to a community complaint about appraisal gaps; Temporary compensating control is the honest Fair Lending call.
• A manufactured-housing lender with dealer-originated files already contained a community complaint about appraisal gaps before HMDA LAR validity and quality edits arrived; no new CRA and Special-Purpose Programs path.
• Provenance on HMDA LAR validity and quality edits after a community complaint about appraisal gaps is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps.
• Flag any disparate-impact table exam-response coordinator cannot explain from HMDA LAR validity and quality edits.
• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• For this Fair Lending CRA and Special-Purpose Programs file, read HMDA LAR validity and quality edits against a community complaint about appraisal gaps and write the one fact that would move a redlining pattern exists for exam-response coordinator.

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 (HMDA LAR validity and quality edits after a community complaint about appraisal gaps). Lead with the Fair Lending option HMDA LAR validity and quality edits can support after a community complaint about appraisal gaps, then the two facts that force it, then the Monday action for exam-response coordinator in a manufactured-housing lender with dealer-originated files.