Comparative Files Show Second-review Bias

Situation

Fair-lending officer in a mortgage company after a pricing-regression spike has one working extract — small-business decline comparative file set — after a board asking if the bank should settle a matched-pair study. If small-business decline comparative file set cannot support comparative files show second-review, the honest Fair Lending output is hold.

Decision

Fair-lending officer 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 small-business decline comparative file set after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• Fair-lending officer can defend Remove access or reverse the item from small-business decline comparative file set after a board asking if the bank should settle a matched-pair study in a Fair Lending challenge.
• Fair-lending officer cannot defend Remove access or reverse the item from small-business decline comparative file set; Temporary compensating control is what the extract actually supports after a board asking if the bank should settle a matched-pair study.
• A board asking if the bank should settle a matched-pair study never reached the population in small-business decline comparative file set — reopen intake, do not close comparative files show second-review.
• Two facts in small-business decline comparative file set after a board asking if the bank should settle a matched-pair study conflict for fair-lending officer; hold this Pricing and Credit Limits file.

Analysis required

• Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study.
• Flag any disparate-impact table fair-lending officer cannot explain from small-business decline comparative file set.
• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• For this Fair Lending Pricing and Credit Limits file, read small-business decline comparative file set 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 fair-lending officer.

Recommendation