Assess whether comparative files show second-review bias (2c73f3)

Situation

A manufactured-housing lender with dealer-originated files cannot treat a notice that cites 'other' as the principal reason 40% of the time as color commentary on geographic application and origination heat map. Exam-response coordinator must close comparative files show second-review from that extract under Fair Lending / CRA and Special-Purpose Programs.

Decision

Exam-response coordinator in a manufactured-housing lender with dealer-originated files 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 CRA and Special-Purpose Programs 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 manufactured-housing lender with dealer-originated files 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 CRA and Special-Purpose Programs 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

• Flag any disparate-impact table exam-response coordinator cannot explain from geographic application and origination heat map.
• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• Match the adverse-action language to the facts in geographic application and origination heat map.
• For this Fair Lending CRA and Special-Purpose Programs 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 comparative files show second-review for exam-response coordinator.