Assess whether a redlining pattern exists after controls (53c70f)

Situation

After a CRA PE that called the assessment area too narrow, appraisal-gap outcomes in majority-minority tracts is what community-development lender can touch in an institution preparing for a redlining exam. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this CRA and Special-Purpose Programs file.

Decision

Community-development lender in an institution preparing for a redlining exam 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

• Community-development lender can defend Remove access or reverse the item from appraisal-gap outcomes in majority-minority tracts after a CRA PE that called the assessment area too narrow in a Fair Lending challenge.
• Community-development lender cannot defend Remove access or reverse the item from appraisal-gap outcomes in majority-minority tracts; Temporary compensating control is what the extract actually supports after a CRA PE that called the assessment area too narrow.
• A CRA PE that called the assessment area too narrow never reached the population in appraisal-gap outcomes in majority-minority tracts — reopen intake, do not close a redlining pattern exists.
• Two facts in appraisal-gap outcomes in majority-minority tracts after a CRA PE that called the assessment area too narrow conflict for community-development lender; hold this CRA and Special-Purpose Programs file.

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 community-development lender cannot explain from appraisal-gap outcomes in majority-minority tracts.
• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• For this Fair Lending CRA and Special-Purpose Programs 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 a redlining pattern exists for community-development lender.