Assess whether comparative files show second-review bias (e4b94c)

Situation

Comparative files show second-review sits with second-review underwriter because an underwriter chat that used coded language hit a small-business desk using a new vendor score. Evidence is underwriting exception log by branch; write the Fair Lending Redlining and HMDA Data option that extract can carry.

Decision

Second-review underwriter in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using underwriting exception log by branch after an underwriter chat that used coded language.

Hypotheses to test

• An underwriter chat that used coded language is noise around an already-controlled Redlining and HMDA Data process in a small-business desk using a new vendor score, given underwriting exception log by branch.
• An underwriter chat that used coded language is the event in underwriting exception log by branch that forces Remove access or reverse the item for second-review underwriter under Fair Lending.
• Underwriting exception log by branch shows a one-file miss after an underwriter chat that used coded language, not a Redlining and HMDA Data program failure.
• Underwriting exception log by branch cannot decide comparative files show second-review yet after an underwriter chat that used coded language; hold is the only Fair Lending close a small-business desk using a new vendor score can defend.

Analysis required

• Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language.
• Flag any disparate-impact table second-review underwriter cannot explain from underwriting exception log by branch.
• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• For this Fair Lending Redlining and HMDA Data file, read underwriting exception log by branch against an underwriter chat that used coded language and write the one fact that would move comparative files show second-review for second-review underwriter.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (underwriting exception log by branch after an underwriter chat that used coded language). The follow-on Redlining and HMDA Data action is what second-review underwriter does next: implement the option, assign an owner, and log the missing fact.