Assess whether comparative files show second-review bias (245654)

Situation

Comparative files show second-review sits with model-risk partner for credit scoring because a marketing mailer that skipped majority-minority tracts hit a credit-card issuer changing line-assignment logic. Evidence is mortgage pricing residual by prohibited-basis group; write the Fair Lending CRA and Special-Purpose Programs option that extract can carry.

Decision

Model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using mortgage pricing residual by prohibited-basis group after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• The population in mortgage pricing residual by prohibited-basis group is the one a marketing mailer that skipped majority-minority tracts named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file.
• The population in mortgage pricing residual by prohibited-basis group is adjacent only to a marketing mailer that skipped majority-minority tracts; Temporary compensating control is the honest Fair Lending call.
• A credit-card issuer changing line-assignment logic already contained a marketing mailer that skipped majority-minority tracts before mortgage pricing residual by prohibited-basis group arrived; no new CRA and Special-Purpose Programs path.
• Provenance on mortgage pricing residual by prohibited-basis group after a marketing mailer that skipped majority-minority tracts is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group.
• Check HMDA coding and underwriting policy against comparative files show second-review.
• Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts.
• For this Fair Lending CRA and Special-Purpose Programs file, read mortgage pricing residual by prohibited-basis group against a marketing mailer that skipped majority-minority tracts and write the one fact that would move comparative files show second-review for model-risk partner for credit scoring.