Assess whether a redlining pattern exists after controls (96a74e)

Situation

After a marketing mailer that skipped majority-minority tracts, manufactured-housing dealer overlay notes is what model-risk partner for credit scoring 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 Examination and Notices file.

Decision

Model-risk partner for credit scoring 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 manufactured-housing dealer overlay notes after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Model-risk partner for credit scoring can defend Remove access or reverse the item from manufactured-housing dealer overlay notes after a marketing mailer that skipped majority-minority tracts in a Fair Lending challenge.
• Model-risk partner for credit scoring cannot defend Remove access or reverse the item from manufactured-housing dealer overlay notes; Temporary compensating control is what the extract actually supports after a marketing mailer that skipped majority-minority tracts.
• A marketing mailer that skipped majority-minority tracts never reached the population in manufactured-housing dealer overlay notes — reopen intake, do not close a redlining pattern exists.
• Two facts in manufactured-housing dealer overlay notes after a marketing mailer that skipped majority-minority tracts conflict for model-risk partner for credit scoring; hold this Examination and Notices file.

Analysis required

• Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend.
• Match the adverse-action language to the facts in manufactured-housing dealer overlay notes.
• Check HMDA coding and underwriting policy against a redlining pattern exists.
• For this Fair Lending Examination and Notices file, read manufactured-housing dealer overlay notes against a marketing mailer that skipped majority-minority tracts and write the one fact that would move a redlining pattern exists for model-risk partner for credit scoring.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (manufactured-housing dealer overlay notes after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option manufactured-housing dealer overlay notes can support after a marketing mailer that skipped majority-minority tracts, then the two facts that force it, then the Monday action for model-risk partner for credit scoring in a lender expanding into majority-minority census tracts.