Assess whether line assignments have a disparate impact the bank will defend

SITUATION Geographic application and origination heat map arrived with a vendor score change with no disparate-impact test. Fair-lending officer in a mortgage company after a pricing-regression spike still has an evidence gap on whether line assignments have a disparate impact the bank will defend.

DECISION Fair-lending officer 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 geographic application and origination heat map after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. The population in geographic application and origination heat map is the one a vendor score change with no disparate-impact test named, so Remove access or reverse the item follows for this Pricing and Credit Limits file. 2. The population in geographic application and origination heat map is adjacent only to a vendor score change with no disparate-impact test; Temporary compensating control is the honest Fair Lending call. 3. A mortgage company after a pricing-regression spike already contained a vendor score change with no disparate-impact test before geographic application and origination heat map arrived; no new Pricing and Credit Limits path. 4. Provenance on geographic application and origination heat map after a vendor score change with no disparate-impact test is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test. 2. Flag any disparate-impact table fair-lending officer cannot explain from geographic application and origination heat map. 3. Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend. 4. For this Fair Lending Pricing and Credit Limits file, read geographic application and origination heat map against a vendor score change with no disparate-impact test and write the one fact that would move line assignments have a for fair-lending officer.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (geographic application and origination heat map after a vendor score change with no disparate-impact test). Lead with the Fair Lending option geographic application and origination heat map can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for fair-lending officer in a mortgage company after a pricing-regression spike.