Assess whether a redlining pattern exists after controls after a marketing

Situation

Community-development lender owns a redlining pattern exists inside a manufactured-housing lender with dealer-originated files with model-reason-code mapping that does not match notices as the only packet. A marketing mailer that skipped majority-minority tracts is what changed the clock for this Fair Lending Examination and Notices file.

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 model-reason-code mapping that does not match notices after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• A marketing mailer that skipped majority-minority tracts is noise around an already-controlled Examination and Notices process in a manufactured-housing lender with dealer-originated files, given model-reason-code mapping that does not match notices.
• A marketing mailer that skipped majority-minority tracts is the event in model-reason-code mapping that does not match notices that forces Remove access or reverse the item for community-development lender under Fair Lending.
• Model-reason-code mapping that does not match notices shows a one-file miss after a marketing mailer that skipped majority-minority tracts, not a Examination and Notices program failure.
• Model-reason-code mapping that does not match notices cannot decide a redlining pattern exists yet after a marketing mailer that skipped majority-minority tracts; hold is the only Fair Lending close a manufactured-housing lender with dealer-originated files can defend.

Analysis required

• 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 model-reason-code mapping that does not match notices.
• Check HMDA coding and underwriting policy against a redlining pattern exists.
• For this Fair Lending Examination and Notices file, read model-reason-code mapping that does not match notices against a marketing mailer that skipped majority-minority tracts and write the one fact that would move a redlining pattern exists for community-development lender.

Recommendation