Assess whether comparative files show second-review bias (75e05f)

Situation

A mortgage company after a pricing-regression spike cannot treat a vendor score change with no disparate-impact test as color commentary on underwriting exception log by branch. CRA strategist must close comparative files show second-review from that extract under Fair Lending / CRA and Special-Purpose Programs.

Decision

CRA strategist 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 underwriting exception log by branch after a vendor score change with no disparate-impact test.

Hypotheses to test

• CRA strategist can defend Remove access or reverse the item from underwriting exception log by branch after a vendor score change with no disparate-impact test in a Fair Lending challenge.
• CRA strategist cannot defend Remove access or reverse the item from underwriting exception log by branch; Temporary compensating control is what the extract actually supports after a vendor score change with no disparate-impact test.
• A vendor score change with no disparate-impact test never reached the population in underwriting exception log by branch — reopen intake, do not close comparative files show second-review.
• Two facts in underwriting exception log by branch after a vendor score change with no disparate-impact test conflict for CRA strategist; hold this CRA and Special-Purpose Programs file.

Analysis required

• 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.
• Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test.
• For this Fair Lending CRA and Special-Purpose Programs file, read underwriting exception log by branch against a vendor score change with no disparate-impact test and write the one fact that would move comparative files show second-review for CRA strategist.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (underwriting exception log by branch after a vendor score change with no disparate-impact test). The follow-on CRA and Special-Purpose Programs action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.