Assess whether notices match the actual decisioning reasons (474009)

SITUATION After a branch that stopped taking applications in one ZIP, appraisal-gap outcomes in majority-minority tracts is what second-review underwriter can touch in a credit union rolling out a special-purpose credit program. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Examination and Notices file.

DECISION Second-review underwriter in a credit union rolling out a special-purpose credit program 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 branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. The population in appraisal-gap outcomes in majority-minority tracts is the one a branch that stopped taking applications in one ZIP named, so Remove access or reverse the item follows for this Examination and Notices file. 2. The population in appraisal-gap outcomes in majority-minority tracts is adjacent only to a branch that stopped taking applications in one ZIP; Temporary compensating control is the honest Fair Lending call. 3. A credit union rolling out a special-purpose credit program already contained a branch that stopped taking applications in one ZIP before appraisal-gap outcomes in majority-minority tracts arrived; no new Examination and Notices path. 4. Provenance on appraisal-gap outcomes in majority-minority tracts after a branch that stopped taking applications in one ZIP is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against notices match the actual. 2. Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP. 3. Flag any disparate-impact table second-review underwriter cannot explain from appraisal-gap outcomes in majority-minority tracts. 4. For this Fair Lending Examination and Notices file, read appraisal-gap outcomes in majority-minority tracts against a branch that stopped taking applications in one ZIP and write the one fact that would move notices match the actual for second-review underwriter.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (appraisal-gap outcomes in majority-minority tracts after a branch that stopped taking applications in one ZIP). The follow-on Examination and Notices action is what second-review underwriter does next: implement the option, assign an owner, and log the missing fact.