Assess whether a redlining pattern exists after controls (02472f)

Situation

A redlining pattern exists sits with adverse-action notice operations lead because a notice that cites 'other' as the principal reason 40% of the time hit a lender expanding into majority-minority census tracts. Evidence is geographic application and origination heat map; write the Fair Lending Redlining and HMDA Data option that extract can carry.

Decision

Adverse-action notice operations lead in a lender expanding into majority-minority census tracts must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using geographic application and origination heat map after a notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• The population in geographic application and origination heat map is the one a notice that cites 'other' as the principal reason 40% of the time named, so Remove access or reverse the item follows for this Redlining and HMDA Data file.
• The population in geographic application and origination heat map is adjacent only to a notice that cites 'other' as the principal reason 40% of the time; Temporary compensating control is the honest Fair Lending call.
• A lender expanding into majority-minority census tracts already contained a notice that cites 'other' as the principal reason 40% of the time before geographic application and origination heat map arrived; no new Redlining and HMDA Data path.
• Provenance on geographic application and origination heat map after a notice that cites 'other' as the principal reason 40% of the time is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend.
• Match the adverse-action language to the facts in geographic application and origination heat map.
• Check HMDA coding and underwriting policy against a redlining pattern exists.
• For this Fair Lending Redlining and HMDA Data file, read geographic application and origination heat map against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move a redlining pattern exists for adverse-action notice operations lead.

Recommendation