Assess whether a redlining pattern exists after controls (2e55e5)

Situation

Adverse-action notice operations lead in a small-business desk using a new vendor score has one working extract — small-business decline comparative file set — after a SPCP that originated almost no loans to the intended class. If small-business decline comparative file set cannot support a redlining pattern exists, the honest Fair Lending output is hold.

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

Hypotheses to test

• The population in small-business decline comparative file set is the one a SPCP that originated almost no loans to the intended class named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file.
• The population in small-business decline comparative file set is adjacent only to a SPCP that originated almost no loans to the intended class; Temporary compensating control is the honest Fair Lending call.
• A small-business desk using a new vendor score already contained a SPCP that originated almost no loans to the intended class before small-business decline comparative file set arrived; no new CRA and Special-Purpose Programs path.
• Provenance on small-business decline comparative file set after a SPCP that originated almost no loans to the intended class is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Flag any disparate-impact table adverse-action notice operations lead cannot explain from small-business decline comparative file set.
• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• Match the adverse-action language to the facts in small-business decline comparative file set.
• For this Fair Lending CRA and Special-Purpose Programs 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 a redlining pattern exists for adverse-action notice operations lead.

Recommendation