Assess whether to pause a product pending a lookback (c77456)

SITUATION In a manufactured-housing lender with dealer-originated files, appraisal-gap outcomes in majority-minority tracts is the evidence after an underwriter chat that used coded language. Fair-lending officer has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data close using appraisal-gap outcomes in majority-minority tracts.

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 an underwriter chat that used coded language.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; appraisal-gap outcomes in majority-minority tracts already has the discriminator after an underwriter chat that used coded language. 2. Keep Temporary compensating control in force until appraisal-gap outcomes in majority-minority tracts is completed after an underwriter chat that used coded language for fair-lending officer. 3. Treat appraisal-gap outcomes in majority-minority tracts as Approve a documented exception because both readings appear after an underwriter chat that used coded language. 4. Refuse a Fair Lending close: fair-lending officer does not have the decision to pause a product turns on in appraisal-gap outcomes in majority-minority tracts.

ANALYSIS REQUIRED 1. Flag any disparate-impact table fair-lending officer cannot explain from appraisal-gap outcomes in majority-minority tracts. 2. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 3. Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts. 4. For this Fair Lending Redlining and HMDA Data file, read appraisal-gap outcomes in majority-minority tracts against an underwriter chat that used coded language 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 an underwriter chat that used coded language). If appraisal-gap outcomes in majority-minority tracts cannot force a Fair Lending label under Redlining and HMDA Data, stop. If appraisal-gap outcomes in majority-minority tracts after an underwriter chat that used coded language cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Redlining and HMDA Data close, fair-lending officer must do not infer a control or scheme beyond the transaction and entitlement evidence.