Assess whether comparative files show second-review bias (66d531)

Situation

HMDA data-quality manager owns comparative files show second-review inside a credit-card issuer changing line-assignment logic with small-business decline comparative file set 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

HMDA data-quality manager in a credit-card issuer changing line-assignment logic 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 marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• The population in small-business decline comparative file set is the one a marketing mailer that skipped majority-minority tracts named, so Remove access or reverse the item follows for this Redlining and HMDA Data file.
• The population in small-business decline comparative file set is adjacent only to a marketing mailer that skipped majority-minority tracts; Temporary compensating control is the honest Fair Lending call.
• A credit-card issuer changing line-assignment logic already contained a marketing mailer that skipped majority-minority tracts before small-business decline comparative file set arrived; no new Redlining and HMDA Data path.
• Provenance on small-business decline comparative file set after a marketing mailer that skipped majority-minority tracts is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts.
• Flag any disparate-impact table HMDA data-quality manager cannot explain from small-business decline comparative file set.
• Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend.
• For this Fair Lending Redlining and HMDA Data file, read small-business decline comparative file set against a marketing mailer that skipped majority-minority tracts and write the one fact that would move comparative files show second-review for HMDA data-quality manager.

Recommendation