Assess whether line assignments have a disparate impact the bank will defend

Situation

In a lender expanding into majority-minority census tracts, underwriting exception log by branch is the evidence after a notice that cites 'other' as the principal reason 40% of the time. Model-risk partner for credit scoring has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices close using underwriting exception log by branch.

Decision

Model-risk partner for credit scoring in a lender expanding into majority-minority census tracts must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using underwriting exception log by branch after a notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• The population in underwriting exception log by branch 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 Examination and Notices file.
• The population in underwriting exception log by branch 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 lender expanding into majority-minority census tracts already contained a notice that cites 'other' as the principal reason 40% of the time before underwriting exception log by branch arrived; no new Examination and Notices path.
• Provenance on underwriting exception log by branch 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

• Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time.
• Flag any disparate-impact table model-risk partner for credit scoring cannot explain from underwriting exception log by branch.
• Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend.
• For this Fair Lending Examination and Notices file, read underwriting exception log by branch against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move line assignments have a for model-risk partner for credit scoring.