Assess whether a redlining pattern exists after controls from appraisal-gap

Situation

CRA strategist in a manufactured-housing lender with dealer-originated files has one working extract — appraisal-gap outcomes in majority-minority tracts — after a board asking if the bank should settle a matched-pair study. If appraisal-gap outcomes in majority-minority tracts cannot support a redlining pattern exists, the honest Fair Lending output is hold.

Decision

CRA strategist 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 board asking if the bank should settle a matched-pair study.

Hypotheses to test

• The population in appraisal-gap outcomes in majority-minority tracts is the one a board asking if the bank should settle a matched-pair study named, so Remove access or reverse the item follows for this Pricing and Credit Limits file.
• The population in appraisal-gap outcomes in majority-minority tracts is adjacent only to a board asking if the bank should settle a matched-pair study; Temporary compensating control is the honest Fair Lending call.
• A manufactured-housing lender with dealer-originated files already contained a board asking if the bank should settle a matched-pair study before appraisal-gap outcomes in majority-minority tracts arrived; no new Pricing and Credit Limits path.
• Provenance on appraisal-gap outcomes in majority-minority tracts after a board asking if the bank should settle a matched-pair study is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Flag any disparate-impact table CRA strategist 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.
• Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts.
• For this Fair Lending Pricing and Credit Limits file, read appraisal-gap outcomes in majority-minority tracts against a board asking if the bank should settle a matched-pair study and write the one fact that would move a redlining pattern exists for CRA strategist.

Recommendation