Assess whether a redlining pattern exists after controls (e605dd)

Situation

The desk packet is underwriting exception log by branch after a notice that cites 'other' as the principal reason 40% of the time. Fair-lending officer in a manufactured-housing lender with dealer-originated files has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data file.

Decision

Fair-lending officer 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 underwriting exception log by branch after a notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• Underwriting exception log by branch reads as Remove access or reverse the item once a notice that cites 'other' as the principal reason 40% of the time is lined up to the same Fair Lending population.
• Underwriting exception log by branch is closer to Temporary compensating control after a notice that cites 'other' as the principal reason 40% of the time; Remove access or reverse the item would over-claim this Redlining and HMDA Data extract.
• Approve a documented exception is still live in underwriting exception log by branch for fair-lending officer in a manufactured-housing lender with dealer-originated files.
• Underwriting exception log by branch is missing the fact fair-lending officer needs after a notice that cites 'other' as the principal reason 40% of the time; stop this Fair Lending close.

Analysis required

• Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time.
• Flag any disparate-impact table fair-lending officer cannot explain from underwriting exception log by branch.
• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• For this Fair Lending Redlining and HMDA Data file, read underwriting exception log by branch against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move a redlining pattern exists for fair-lending officer.

Recommendation