Assess whether comparative files show second-review bias (e84fa7)

Situation

Second-review underwriter owns comparative files show second-review inside a small-business desk using a new vendor score with CRA assessment-area versus lending footprint as the only packet. A marketing mailer that skipped majority-minority tracts is what changed the clock for this Fair Lending Redlining and HMDA Data file.

Decision

Second-review underwriter in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using CRA assessment-area versus lending footprint after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Second-review underwriter can defend Remove access or reverse the item from CRA assessment-area versus lending footprint after a marketing mailer that skipped majority-minority tracts in a Fair Lending challenge.
• Second-review underwriter cannot defend Remove access or reverse the item from CRA assessment-area versus lending footprint; Temporary compensating control is what the extract actually supports after a marketing mailer that skipped majority-minority tracts.
• A marketing mailer that skipped majority-minority tracts never reached the population in CRA assessment-area versus lending footprint — reopen intake, do not close comparative files show second-review.
• Two facts in CRA assessment-area versus lending footprint after a marketing mailer that skipped majority-minority tracts conflict for second-review underwriter; hold this Redlining and HMDA Data file.

Analysis required

• Check HMDA coding and underwriting policy against comparative files show second-review.
• Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts.
• Flag any disparate-impact table second-review underwriter cannot explain from CRA assessment-area versus lending footprint.
• For this Fair Lending Redlining and HMDA Data file, read CRA assessment-area versus lending footprint against a marketing mailer that skipped majority-minority tracts and write the one fact that would move comparative files show second-review for second-review underwriter.

Recommendation