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

Situation

Community-development lender owns line assignments have a inside a mortgage company after a pricing-regression spike with mortgage pricing residual by prohibited-basis group as the only packet. A marketing mailer that skipped majority-minority tracts is what changed the clock for this Fair Lending Redlining and HMDA Data file.

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 mortgage pricing residual by prohibited-basis group after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• The population in mortgage pricing residual by prohibited-basis group is the one a marketing mailer that skipped majority-minority tracts named, so Remove access or reverse the item follows for this Redlining and HMDA Data file.
• The population in mortgage pricing residual by prohibited-basis group is adjacent only to a marketing mailer that skipped majority-minority tracts; Temporary compensating control is the honest Fair Lending call.
• A mortgage company after a pricing-regression spike already contained a marketing mailer that skipped majority-minority tracts before mortgage pricing residual by prohibited-basis group arrived; no new Redlining and HMDA Data path.
• Provenance on mortgage pricing residual by prohibited-basis group after a marketing mailer that skipped majority-minority tracts is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Flag any disparate-impact table community-development lender cannot explain from mortgage pricing residual by prohibited-basis group.
• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group.
• For this Fair Lending Redlining and HMDA Data file, read mortgage pricing residual by prohibited-basis group against a marketing mailer that skipped majority-minority tracts and write the one fact that would move line assignments have a for community-development lender.

Recommendation