Assess whether a redlining pattern exists after controls (b0ee31)

Situation

A redlining pattern exists sits with fair-lending officer because a marketing mailer that skipped majority-minority tracts hit an institution preparing for a redlining exam. Evidence is small-business decline comparative file set; write the Fair Lending Examination and Notices option that extract can carry.

Decision

Fair-lending officer in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using small-business decline comparative file set after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Small-business decline comparative file set reads as Remove access or reverse the item once a marketing mailer that skipped majority-minority tracts is lined up to the same Fair Lending population.
• Small-business decline comparative file set is closer to Temporary compensating control after a marketing mailer that skipped majority-minority tracts; Remove access or reverse the item would over-claim this Examination and Notices extract.
• Approve a documented exception is still live in small-business decline comparative file set for fair-lending officer in an institution preparing for a redlining exam.
• Small-business decline comparative file set is missing the fact fair-lending officer needs after a marketing mailer that skipped majority-minority tracts; stop this Fair Lending close.

Analysis required

• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• Match the adverse-action language to the facts in small-business decline comparative file set.
• Check HMDA coding and underwriting policy against a redlining pattern exists.
• For this Fair Lending Examination and Notices file, read small-business decline comparative file set against a marketing mailer that skipped majority-minority tracts and write the one fact that would move a redlining pattern exists for fair-lending officer.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (small-business decline comparative file set after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option small-business decline comparative file set can support after a marketing mailer that skipped majority-minority tracts, then the two facts that force it, then the Monday action for fair-lending officer in an institution preparing for a redlining exam.