Whether comparative files show second-review bias from appraisal-gap outcomes

Situation

Comparative files show second-review sits with adverse-action notice operations lead because a marketing mailer that skipped majority-minority tracts hit a credit union rolling out a special-purpose credit program. Evidence is appraisal-gap outcomes in majority-minority tracts; write the Fair Lending Pricing and Credit Limits option that extract can carry.

Decision

Adverse-action notice operations lead in a credit union rolling out a special-purpose credit program must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using appraisal-gap outcomes in majority-minority tracts after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Adverse-action notice operations lead can defend Remove access or reverse the item from appraisal-gap outcomes in majority-minority tracts after a marketing mailer that skipped majority-minority tracts in a Fair Lending challenge.
• Adverse-action notice operations lead cannot defend Remove access or reverse the item from appraisal-gap outcomes in majority-minority tracts; Temporary compensating control is what the extract actually supports after a marketing mailer that skipped majority-minority tracts.
• A marketing mailer that skipped majority-minority tracts never reached the population in appraisal-gap outcomes in majority-minority tracts — reopen intake, do not close comparative files show second-review.
• Two facts in appraisal-gap outcomes in majority-minority tracts after a marketing mailer that skipped majority-minority tracts conflict for adverse-action notice operations lead; hold this Pricing and Credit Limits file.

Analysis required

• Flag any disparate-impact table adverse-action notice operations lead cannot explain from appraisal-gap outcomes in majority-minority tracts.
• Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend.
• Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts.
• For this Fair Lending Pricing and Credit Limits file, read appraisal-gap outcomes in majority-minority tracts against a marketing mailer that skipped majority-minority tracts and write the one fact that would move comparative files show second-review for adverse-action notice operations lead.