Assess whether to pause a product pending a lookback (94c73f)

SITUATION In an institution preparing for a redlining exam, appraisal-gap outcomes in majority-minority tracts is the evidence after a community complaint about appraisal gaps. Community-development lender has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs close using appraisal-gap outcomes in majority-minority tracts.

DECISION Community-development lender 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 appraisal-gap outcomes in majority-minority tracts after a community complaint about appraisal gaps.

HYPOTHESES TO TEST 1. Community-development lender can defend Remove access or reverse the item from appraisal-gap outcomes in majority-minority tracts after a community complaint about appraisal gaps in a Fair Lending challenge. 2. Community-development lender cannot defend Remove access or reverse the item from appraisal-gap outcomes in majority-minority tracts; Temporary compensating control is what the extract actually supports after a community complaint about appraisal gaps. 3. A community complaint about appraisal gaps never reached the population in appraisal-gap outcomes in majority-minority tracts — reopen intake, do not close to pause a product. 4. Two facts in appraisal-gap outcomes in majority-minority tracts after a community complaint about appraisal gaps conflict for community-development lender; hold this CRA and Special-Purpose Programs file.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern an institution preparing for a redlining exam must defend. 2. Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts. 3. Check HMDA coding and underwriting policy against to pause a product. 4. For this Fair Lending CRA and Special-Purpose Programs file, read appraisal-gap outcomes in majority-minority tracts against a community complaint about appraisal gaps and write the one fact that would move to pause a product for community-development lender.

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 (appraisal-gap outcomes in majority-minority tracts after a community complaint about appraisal gaps). The follow-on CRA and Special-Purpose Programs action is what community-development lender does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on to pause a product, then the evidence in appraisal-gap outcomes in majority-minority tracts, then the action for community-development lender - Hypothesis scorecard against appraisal-gap outcomes in majority-minority tracts: supported / rejected / untestable - Owner and next date for community-development lender in an institution preparing for a redlining exam - What changes to pause a product if a community complaint about appraisal gaps is later withdrawn