Assess whether comparative files show second-review bias after a vendor score

SITUATION Exam-response coordinator in an institution preparing for a redlining exam has one working extract — manufactured-housing dealer overlay notes — after a vendor score change with no disparate-impact test. If manufactured-housing dealer overlay notes cannot support comparative files show second-review, the only defensible Fair Lending output is hold.

DECISION Exam-response coordinator in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using manufactured-housing dealer overlay notes after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. Manufactured-housing dealer overlay notes reads as Remove access or reverse the item once a vendor score change with no disparate-impact test is lined up to the same Fair Lending population. 2. Manufactured-housing dealer overlay notes is closer to Temporary compensating control after a vendor score change with no disparate-impact test; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract. 3. Approve a documented exception is still live in manufactured-housing dealer overlay notes for exam-response coordinator in an institution preparing for a redlining exam. 4. Manufactured-housing dealer overlay notes is missing the fact exam-response coordinator needs after a vendor score change with no disparate-impact test; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against comparative files show second-review. 2. Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test. 3. Flag any disparate-impact table exam-response coordinator cannot explain from manufactured-housing dealer overlay notes. 4. For this Fair Lending Pricing and Credit Limits file, read manufactured-housing dealer overlay notes against a vendor score change with no disparate-impact test and write the one fact that would move comparative files show second-review for exam-response coordinator.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (manufactured-housing dealer overlay notes after a vendor score change with no disparate-impact test). Lead with the Fair Lending option manufactured-housing dealer overlay notes can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for exam-response coordinator in an institution preparing for a redlining exam.