Assess whether comparative files show second-review bias (ad7c81)

Situation

A board asking if the bank should settle a matched-pair study put manufactured-housing dealer overlay notes in front of model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program. This Fair Lending / Redlining and HMDA Data close is comparative files show second-review from manufactured-housing dealer overlay notes, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

Model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using manufactured-housing dealer overlay notes after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• The population in manufactured-housing dealer overlay notes is the one a board asking if the bank should settle a matched-pair study named, so Remove access or reverse the item follows for this Redlining and HMDA Data file.
• The population in manufactured-housing dealer overlay notes is adjacent only to a board asking if the bank should settle a matched-pair study; Temporary compensating control is the honest Fair Lending call.
• A credit union rolling out a special-purpose credit program already contained a board asking if the bank should settle a matched-pair study before manufactured-housing dealer overlay notes arrived; no new Redlining and HMDA Data path.
• Provenance on manufactured-housing dealer overlay notes after a board asking if the bank should settle a matched-pair study 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 manufactured-housing dealer overlay notes.
• Check HMDA coding and underwriting policy against comparative files show second-review.
• Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study.
• For this Fair Lending Redlining and HMDA Data file, read manufactured-housing dealer overlay notes against a board asking if the bank should settle a matched-pair study and write the one fact that would move comparative files show second-review for model-risk partner for credit scoring.