Assess whether comparative files show second-review bias (e833fa)

Situation

Comparative files show second-review sits with second-review underwriter because a DOJ or CFPB monitor request for pricing files 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 a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• Authorize Remove access or reverse the item now; underwriting exception log by branch already has the discriminator after a DOJ or CFPB monitor request for pricing files.
• Keep Temporary compensating control in force until underwriting exception log by branch is completed after a DOJ or CFPB monitor request for pricing files for second-review underwriter.
• Treat underwriting exception log by branch as Approve a documented exception because both readings appear after a DOJ or CFPB monitor request for pricing files.
• Refuse a Fair Lending close: second-review underwriter does not have the page comparative files show second-review turns on in underwriting exception log by branch.

Analysis required

• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• Match the adverse-action language to the facts in underwriting exception log by branch.
• Check HMDA coding and underwriting policy against comparative files show second-review.
• For this Fair Lending Redlining and HMDA Data file, read underwriting exception log by branch against a DOJ or CFPB monitor request for pricing files and write the one fact that would move comparative files show second-review for second-review underwriter.

Recommendation

Second-review underwriter should take Temporary compensating control on comparative files show second-review unless underwriting exception log by branch after a DOJ or CFPB monitor request for pricing files already proves Remove access or reverse the item for this Redlining and HMDA Data packet in a small-business desk using a new vendor score. Keep Approve a documented exception live only while underwriting exception log by branch is missing the page comparative files show second-review turns on. The working test on underwriting exception log by branch is whether Test a documented exception versus a pattern a small-business desk using a new vendor scor.