Assess whether comparative files show second-review bias (ab37b4)

Situation

Comparative files show second-review sits with fair-lending officer because an exception rate twice as high for one group after credit controls hit a manufactured-housing lender with dealer-originated files. Evidence is credit-card limit assignment disparity table; write the Fair Lending Redlining and HMDA Data option that extract can carry.

Decision

Fair-lending officer 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 credit-card limit assignment disparity table after an exception rate twice as high for one group after credit controls.

Hypotheses to test

• Fair-lending officer can defend Remove access or reverse the item from credit-card limit assignment disparity table after an exception rate twice as high for one group after credit controls in a Fair Lending challenge.
• Fair-lending officer cannot defend Remove access or reverse the item from credit-card limit assignment disparity table; Temporary compensating control is what the extract actually supports after an exception rate twice as high for one group after credit controls.
• An exception rate twice as high for one group after credit controls never reached the population in credit-card limit assignment disparity table — reopen intake, do not close comparative files show second-review.
• Two facts in credit-card limit assignment disparity table after an exception rate twice as high for one group after credit controls conflict for fair-lending officer; hold this Redlining and HMDA Data file.

Analysis required

• Flag any disparate-impact table fair-lending officer cannot explain from credit-card limit assignment disparity table.
• 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 credit-card limit assignment disparity table.
• For this Fair Lending Redlining and HMDA Data file, read credit-card limit assignment disparity table against an exception rate twice as high for one group after credit controls and write the one fact that would move comparative files show second-review for fair-lending officer.

Recommendation