Assess whether a redlining pattern exists after controls (ae7d4c)

Situation

A redlining pattern exists sits with adverse-action notice operations lead because a DOJ or CFPB monitor request for pricing files hit a small-business desk using a new vendor score. Evidence is model-reason-code mapping that does not match notices; write the Fair Lending CRA and Special-Purpose Programs option that extract can carry.

Decision

Adverse-action notice operations lead 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 model-reason-code mapping that does not match notices after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• A DOJ or CFPB monitor request for pricing files is noise around an already-controlled CRA and Special-Purpose Programs process in a small-business desk using a new vendor score, given model-reason-code mapping that does not match notices.
• A DOJ or CFPB monitor request for pricing files is the event in model-reason-code mapping that does not match notices that forces Remove access or reverse the item for adverse-action notice operations lead under Fair Lending.
• Model-reason-code mapping that does not match notices shows a one-file miss after a DOJ or CFPB monitor request for pricing files, not a CRA and Special-Purpose Programs program failure.
• Model-reason-code mapping that does not match notices cannot decide a redlining pattern exists yet after a DOJ or CFPB monitor request for pricing files; hold is the only Fair Lending close a small-business desk using a new vendor score can defend.

Analysis required

• Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files.
• Flag any disparate-impact table adverse-action notice operations lead cannot explain from model-reason-code mapping that does not match notices.
• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• For this Fair Lending CRA and Special-Purpose Programs file, read model-reason-code mapping that does not match notices against a DOJ or CFPB monitor request for pricing files and write the one fact that would move a redlining pattern exists for adverse-action notice operations lead.