Assess whether line assignments have a disparate impact the bank will defend

Situation

Community-development lender owns line assignments have a inside a manufactured-housing lender with dealer-originated files with appraisal-gap outcomes in majority-minority tracts as the only packet. A notice that cites 'other' as the principal reason 40% of the time is what changed the clock for this Fair Lending Examination and Notices file.

Decision

Community-development lender 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 notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• The population in appraisal-gap outcomes in majority-minority tracts is the one a notice that cites 'other' as the principal reason 40% of the time named, so Remove access or reverse the item follows for this Examination and Notices file.
• The population in appraisal-gap outcomes in majority-minority tracts is adjacent only to a notice that cites 'other' as the principal reason 40% of the time; Temporary compensating control is the honest Fair Lending call.
• A manufactured-housing lender with dealer-originated files already contained a notice that cites 'other' as the principal reason 40% of the time before appraisal-gap outcomes in majority-minority tracts arrived; no new Examination and Notices path.
• Provenance on appraisal-gap outcomes in majority-minority tracts after a notice that cites 'other' as the principal reason 40% of the time is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts.
• Check HMDA coding and underwriting policy against line assignments have a.
• Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time.
• For this Fair Lending Examination and Notices file, read appraisal-gap outcomes in majority-minority tracts against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move line assignments have a for community-development lender.