Assess whether comparative files show second-review bias (a5c18f)

Situation

The desk packet is geographic application and origination heat map after a marketing mailer that skipped majority-minority tracts. Adverse-action notice operations lead in a small-business desk using a new vendor score has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs file.

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 geographic application and origination heat map 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 geographic application and origination heat map 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 geographic application and origination heat map; 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 geographic application and origination heat map — reopen intake, do not close comparative files show second-review.
• Two facts in geographic application and origination heat map after a marketing mailer that skipped majority-minority tracts conflict for adverse-action notice operations lead; hold this CRA and Special-Purpose Programs file.

Analysis required

• Match the adverse-action language to the facts in geographic application and origination heat map.
• Check HMDA coding and underwriting policy against comparative files show second-review.
• Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts.
• For this Fair Lending CRA and Special-Purpose Programs file, read geographic application and origination heat map 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.