Assess whether a redlining pattern exists after controls (ac9ec4)

Situation

A redlining pattern exists sits with fair-lending officer because a community complaint about appraisal gaps hit an institution preparing for a redlining exam. Evidence is small-business decline comparative file set; write the Fair Lending Examination and Notices option that extract can carry.

Decision

Fair-lending officer in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using small-business decline comparative file set after a community complaint about appraisal gaps.

Hypotheses to test

• Fair-lending officer can defend Remove access or reverse the item from small-business decline comparative file set after a community complaint about appraisal gaps in a Fair Lending challenge.
• Fair-lending officer cannot defend Remove access or reverse the item from small-business decline comparative file set; Temporary compensating control is what the extract actually supports after a community complaint about appraisal gaps.
• A community complaint about appraisal gaps never reached the population in small-business decline comparative file set — reopen intake, do not close a redlining pattern exists.
• Two facts in small-business decline comparative file set after a community complaint about appraisal gaps conflict for fair-lending officer; hold this Examination and Notices file.

Analysis required

• Check HMDA coding and underwriting policy against a redlining pattern exists.
• Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps.
• Flag any disparate-impact table fair-lending officer cannot explain from small-business decline comparative file set.
• For this Fair Lending Examination and Notices file, read small-business decline comparative file set against a community complaint about appraisal gaps and write the one fact that would move a redlining pattern exists for fair-lending officer.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (small-business decline comparative file set after a community complaint about appraisal gaps). If small-business decline comparative file set cannot force a Fair Lending label under Examination and Notices, stop. If small-business decline comparative file set after a community complaint about appraisal gaps cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Examination and Notices close, fair-lending officer must do not infer a control or scheme beyond the transaction and entitlement evidence.