Assess whether comparative files show second-review bias (449e66)

Situation

A mortgage company after a pricing-regression spike cannot treat a board asking if the bank should settle a matched-pair study as color commentary on appraisal-gap outcomes in majority-minority tracts. Community-development lender must close comparative files show second-review from that extract under Fair Lending / Redlining and HMDA Data.

Decision

Community-development lender 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 board asking if the bank should settle a matched-pair study.

Hypotheses to test

• Appraisal-gap outcomes in majority-minority tracts reads as Remove access or reverse the item once a board asking if the bank should settle a matched-pair study is lined up to the same Fair Lending population.
• Appraisal-gap outcomes in majority-minority tracts is closer to Temporary compensating control after a board asking if the bank should settle a matched-pair study; Remove access or reverse the item would over-claim this Redlining and HMDA Data extract.
• Approve a documented exception is still live in appraisal-gap outcomes in majority-minority tracts for community-development lender in a mortgage company after a pricing-regression spike.
• Appraisal-gap outcomes in majority-minority tracts is missing the fact community-development lender needs after a board asking if the bank should settle a matched-pair study; stop this Fair Lending close.

Analysis required

• Check HMDA coding and underwriting policy against comparative files show second-review.
• Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study.
• Flag any disparate-impact table community-development lender cannot explain from appraisal-gap outcomes in majority-minority tracts.
• For this Fair Lending Redlining and HMDA Data file, read appraisal-gap outcomes in majority-minority tracts against a board asking if the bank should settle a matched-pair study and write the one fact that would move comparative files show second-review for community-development lender.

Recommendation