Assess whether a redlining pattern exists after controls (92b4b3)

Situation

After a notice that cites 'other' as the principal reason 40% of the time, small-business decline comparative file set is what community-development lender can touch in a mortgage company after a pricing-regression spike. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Redlining and HMDA Data file.

Decision

Community-development lender 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 small-business decline comparative file set after a notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• The population in small-business decline comparative file set 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 small-business decline comparative file set 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 mortgage company after a pricing-regression spike already contained a notice that cites 'other' as the principal reason 40% of the time before small-business decline comparative file set arrived; no new Redlining and HMDA Data path.
• Provenance on small-business decline comparative file set 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

• Flag any disparate-impact table community-development lender cannot explain from small-business decline comparative file set.
• 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 small-business decline comparative file set.
• For this Fair Lending Redlining and HMDA Data file, read small-business decline comparative file set 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 community-development lender.

Recommendation