Assess whether to pause a product pending a lookback (c43a39)

SITUATION Redlining and HMDA Data work in a manufactured-housing lender with dealer-originated files now turns on to pause a product because a marketing mailer that skipped majority-minority tracts put appraisal-gap outcomes in majority-minority tracts in play. Fair-lending officer should say what appraisal-gap outcomes in majority-minority tracts proves.

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 appraisal-gap outcomes in majority-minority tracts after a marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. A marketing mailer that skipped majority-minority tracts is noise around an already-controlled Redlining and HMDA Data process in a manufactured-housing lender with dealer-originated files, given appraisal-gap outcomes in majority-minority tracts. 2. A marketing mailer that skipped majority-minority tracts is the event in appraisal-gap outcomes in majority-minority tracts that forces Remove access or reverse the item for fair-lending officer under Fair Lending. 3. Appraisal-gap outcomes in majority-minority tracts shows a one-file miss after a marketing mailer that skipped majority-minority tracts, not a Redlining and HMDA Data program failure. 4. Appraisal-gap outcomes in majority-minority tracts cannot decide to pause a product 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 1. Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts. 2. Flag any disparate-impact table fair-lending officer cannot explain from appraisal-gap outcomes in majority-minority tracts. 3. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 4. For this Fair Lending Redlining and HMDA Data file, read appraisal-gap outcomes in majority-minority tracts against a marketing mailer that skipped majority-minority tracts and write the one fact that would move to pause a product for fair-lending officer.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (appraisal-gap outcomes in majority-minority tracts after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option appraisal-gap outcomes in majority-minority tracts can support after a marketing mailer that skipped majority-minority tracts, then the two facts that force it, then the Monday action for fair-lending officer in a manufactured-housing lender with dealer-originated files.