Assess whether a redlining pattern exists after controls (21af91)

Situation

A community complaint about appraisal gaps put CRA assessment-area versus lending footprint in front of community-development lender in a manufactured-housing lender with dealer-originated files. This Fair Lending / Examination and Notices close is a redlining pattern exists from CRA assessment-area versus lending footprint, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

Community-development lender 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 CRA assessment-area versus lending footprint after a community complaint about appraisal gaps.

Hypotheses to test

• The population in CRA assessment-area versus lending footprint is the one a community complaint about appraisal gaps named, so Remove access or reverse the item follows for this Examination and Notices file.
• The population in CRA assessment-area versus lending footprint 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 CRA assessment-area versus lending footprint arrived; no new Examination and Notices path.
• Provenance on CRA assessment-area versus lending footprint 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

• Match the adverse-action language to the facts in CRA assessment-area versus lending footprint.
• Check HMDA coding and underwriting policy against a redlining pattern exists.
• Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps.
• For this Fair Lending Examination and Notices file, read CRA assessment-area versus lending footprint against a community complaint about appraisal gaps and write the one fact that would move a redlining pattern exists for community-development lender.

Recommendation