Assess whether notices match the actual decisioning reasons (82b13a)

SITUATION A small-business desk using a new vendor score cannot treat a SPCP that originated almost no loans to the intended class as incidental context on small-business decline comparative file set. Second-review underwriter must close notices match the actual from that extract under Fair Lending / Redlining and HMDA Data.

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 small-business decline comparative file set after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. Second-review underwriter can defend Remove access or reverse the item from small-business decline comparative file set after a SPCP that originated almost no loans to the intended class in a Fair Lending challenge. 2. Second-review underwriter cannot defend Remove access or reverse the item from small-business decline comparative file set; Temporary compensating control is what the extract actually supports after a SPCP that originated almost no loans to the intended class. 3. A SPCP that originated almost no loans to the intended class never reached the population in small-business decline comparative file set — reopen intake, do not close notices match the actual. 4. Two facts in small-business decline comparative file set after a SPCP that originated almost no loans to the intended class conflict for second-review underwriter; hold this Redlining and HMDA Data file.

ANALYSIS REQUIRED 1. Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class. 2. Flag any disparate-impact table second-review underwriter cannot explain from small-business decline comparative file set. 3. Test a documented exception versus a pattern a small-business desk using a new vendor score must defend. 4. For this Fair Lending Redlining and HMDA Data file, read small-business decline comparative file set against a SPCP that originated almost no loans to the intended class and write the one fact that would move notices match the actual for second-review underwriter.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (small-business decline comparative file set after a SPCP that originated almost no loans to the intended class). The follow-on Redlining and HMDA Data action is what second-review underwriter does next: implement the option, assign an owner, and log the missing fact.