Whether notices match the actual decisioning reasons from model-reason-code

Situation

Pricing and Credit Limits work in a mortgage company after a pricing-regression spike now turns on notices match the actual because a community complaint about appraisal gaps put model-reason-code mapping that does not match notices in play. Fair-lending officer should say what model-reason-code mapping that does not match notices proves.

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 model-reason-code mapping that does not match notices after a community complaint about appraisal gaps.

Hypotheses to test

• The population in model-reason-code mapping that does not match notices is the one a community complaint about appraisal gaps named, so Remove access or reverse the item follows for this Pricing and Credit Limits file.
• The population in model-reason-code mapping that does not match notices is adjacent only to a community complaint about appraisal gaps; Temporary compensating control is the honest Fair Lending call.
• A mortgage company after a pricing-regression spike already contained a community complaint about appraisal gaps before model-reason-code mapping that does not match notices arrived; no new Pricing and Credit Limits path.
• Provenance on model-reason-code mapping that does not match notices after a community complaint about appraisal gaps is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Check HMDA coding and underwriting policy against notices match the actual.
• Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps.
• Flag any disparate-impact table fair-lending officer cannot explain from model-reason-code mapping that does not match notices.
• For this Fair Lending Pricing and Credit Limits file, read model-reason-code mapping that does not match notices against a community complaint about appraisal gaps and write the one fact that would move notices match the actual 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 (model-reason-code mapping that does not match notices after a community complaint about appraisal gaps). The follow-on Pricing and Credit Limits action is what fair-lending officer does next: implement the option, assign an owner, and log the missing fact.