Assess whether comparative files show second-review bias (d347d0)

Situation

In a mortgage company after a pricing-regression spike, appraisal-gap outcomes in majority-minority tracts is the evidence after a CRA PE that called the assessment area too narrow. Exam-response coordinator has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices close using appraisal-gap outcomes in majority-minority tracts.

Decision

Exam-response coordinator in a mortgage company after a pricing-regression spike 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 CRA PE that called the assessment area too narrow.

Hypotheses to test

• Authorize Remove access or reverse the item now; appraisal-gap outcomes in majority-minority tracts already has the discriminator after a CRA PE that called the assessment area too narrow.
• Keep Temporary compensating control in force until appraisal-gap outcomes in majority-minority tracts is completed after a CRA PE that called the assessment area too narrow for exam-response coordinator.
• Treat appraisal-gap outcomes in majority-minority tracts as Approve a documented exception because both readings appear after a CRA PE that called the assessment area too narrow.
• Refuse a Fair Lending close: exam-response coordinator does not have the page comparative files show second-review turns on in appraisal-gap outcomes in majority-minority tracts.

Analysis required

• Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow.
• Flag any disparate-impact table exam-response coordinator cannot explain from appraisal-gap outcomes in majority-minority tracts.
• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• For this Fair Lending Examination and Notices file, read appraisal-gap outcomes in majority-minority tracts against a CRA PE that called the assessment area too narrow and write the one fact that would move comparative files show second-review for exam-response coordinator.

Recommendation