Assess whether comparative files show second-review bias (cfd6dc)

Situation

Comparative files show second-review sits with community-development lender because a SPCP that originated almost no loans to the intended class hit a mortgage company after a pricing-regression spike. Evidence is adverse-action notice principal-reason sample; write the Fair Lending Redlining and HMDA Data option that extract can carry.

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 adverse-action notice principal-reason sample after a SPCP that originated almost no loans to the intended class.

Hypotheses to test

• The population in adverse-action notice principal-reason sample is the one a SPCP that originated almost no loans to the intended class named, so Remove access or reverse the item follows for this Redlining and HMDA Data file.
• The population in adverse-action notice principal-reason sample is adjacent only to a SPCP that originated almost no loans to the intended class; Temporary compensating control is the honest Fair Lending call.
• A mortgage company after a pricing-regression spike already contained a SPCP that originated almost no loans to the intended class before adverse-action notice principal-reason sample arrived; no new Redlining and HMDA Data path.
• Provenance on adverse-action notice principal-reason sample after a SPCP that originated almost no loans to the intended class 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 adverse-action notice principal-reason sample.
• Check HMDA coding and underwriting policy against comparative files show second-review.
• Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class.
• For this Fair Lending Redlining and HMDA Data file, read adverse-action notice principal-reason sample against a SPCP that originated almost no loans to the intended class and write the one fact that would move comparative files show second-review for community-development lender.

Recommendation