Assess whether a redlining pattern exists after controls (bbdb97)

Situation

A vendor score change with no disparate-impact test put manufactured-housing dealer overlay notes in front of CRA strategist in a mortgage company after a pricing-regression spike. This Fair Lending / CRA and Special-Purpose Programs close is a redlining pattern exists from manufactured-housing dealer overlay notes, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

CRA strategist 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 manufactured-housing dealer overlay notes after a vendor score change with no disparate-impact test.

Hypotheses to test

• Manufactured-housing dealer overlay notes after a vendor score change with no disparate-impact test supports Remove access or reverse the item for a redlining pattern exists if CRA strategist can match the same CRA and Special-Purpose Programs population in a mortgage company after a pricing-regression spike.
• Manufactured-housing dealer overlay notes after a vendor score change with no disparate-impact test is closer to Temporary compensating control; calling Remove access or reverse the item would over-claim this Fair Lending extract.
• Flag any disparate-impact table CRA strategist cannot explain from manufactured-housing dealer overlay notes. is still a live third reading of manufactured-housing dealer overlay notes that CRA strategist has not closed.
• Manufactured-housing dealer overlay notes after a vendor score change with no disparate-impact test does not yet name the fact a redlining pattern exists turns on, so CRA strategist should leave Fair Lending unresolved.

Analysis required

• Flag any disparate-impact table CRA strategist cannot explain from manufactured-housing dealer overlay notes.
• 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 manufactured-housing dealer overlay notes.
• For this Fair Lending CRA and Special-Purpose Programs file, read manufactured-housing dealer overlay notes against a vendor score change with no disparate-impact test and write the one fact that would move a redlining pattern exists for CRA strategist.