Assess whether comparative files show second-review bias (96c95f)

Situation

A branch that stopped taking applications in one ZIP put underwriting exception log by branch in front of adverse-action notice operations lead in a small-business desk using a new vendor score. This Fair Lending / CRA and Special-Purpose Programs close is comparative files show second-review from underwriting exception log by branch, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

Adverse-action notice operations lead 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 a branch that stopped taking applications in one ZIP.

Hypotheses to test

• A branch that stopped taking applications in one ZIP is noise around an already-controlled CRA and Special-Purpose Programs process in a small-business desk using a new vendor score, given underwriting exception log by branch.
• A branch that stopped taking applications in one ZIP is the event in underwriting exception log by branch that forces Remove access or reverse the item for adverse-action notice operations lead under Fair Lending.
• Underwriting exception log by branch shows a one-file miss after a branch that stopped taking applications in one ZIP, not a CRA and Special-Purpose Programs program failure.
• Underwriting exception log by branch cannot decide comparative files show second-review yet after a branch that stopped taking applications in one ZIP; 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 a branch that stopped taking applications in one ZIP.
• Flag any disparate-impact table adverse-action notice operations lead 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 CRA and Special-Purpose Programs file, read underwriting exception log by branch against a branch that stopped taking applications in one ZIP and write the one fact that would move comparative files show second-review for adverse-action notice operations lead.