Assess whether a redlining pattern exists after controls (887683)

Situation

Underwriting exception log by branch arrived with a community complaint about appraisal gaps for community-development lender. That is a Fair Lending CRA and Special-Purpose Programs decision on a redlining pattern exists in an institution preparing for a redlining exam.

Decision

Community-development lender 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 underwriting exception log by branch after a community complaint about appraisal gaps.

Hypotheses to test

• Community-development lender can defend Remove access or reverse the item from underwriting exception log by branch after a community complaint about appraisal gaps in a Fair Lending challenge.
• Community-development lender cannot defend Remove access or reverse the item from underwriting exception log by branch; Temporary compensating control is what the extract actually supports after a community complaint about appraisal gaps.
• A community complaint about appraisal gaps never reached the population in underwriting exception log by branch — reopen intake, do not close a redlining pattern exists.
• Two facts in underwriting exception log by branch after a community complaint about appraisal gaps conflict for community-development lender; hold this CRA and Special-Purpose Programs file.

Analysis required

• Flag any disparate-impact table community-development lender cannot explain from underwriting exception log by branch.
• 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 underwriting exception log by branch.
• For this Fair Lending CRA and Special-Purpose Programs file, read underwriting exception log by branch against a community complaint about appraisal gaps and write the one fact that would move a redlining pattern exists for community-development lender.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (underwriting exception log by branch after a community complaint about appraisal gaps). The follow-on CRA and Special-Purpose Programs action is what community-development lender does next: implement the option, assign an owner, and log the missing fact.