Assess whether a redlining pattern exists after controls after a community

Situation

The desk packet is appraisal-gap outcomes in majority-minority tracts after a community complaint about appraisal gaps. Fair-lending officer in a manufactured-housing lender with dealer-originated files has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data file.

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 a community complaint about appraisal gaps.

Hypotheses to test

• The population in appraisal-gap outcomes in majority-minority tracts is the one a community complaint about appraisal gaps named, so Remove access or reverse the item follows for this Redlining and HMDA Data file.
• The population in appraisal-gap outcomes in majority-minority tracts is adjacent only to a community complaint about appraisal gaps; Temporary compensating control is the honest Fair Lending call.
• A manufactured-housing lender with dealer-originated files already contained a community complaint about appraisal gaps before appraisal-gap outcomes in majority-minority tracts arrived; no new Redlining and HMDA Data path.
• Provenance on appraisal-gap outcomes in majority-minority tracts after a community complaint about appraisal gaps is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps.
• Flag any disparate-impact table fair-lending officer cannot explain from appraisal-gap outcomes in majority-minority tracts.
• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• For this Fair Lending Redlining and HMDA Data file, read appraisal-gap outcomes in majority-minority tracts against a community complaint about appraisal gaps and write the one fact that would move a redlining pattern exists for fair-lending officer.

Recommendation