Assess whether comparative files show second-review bias (46bfa9)

Situation

In a small-business desk using a new vendor score, appraisal-gap outcomes in majority-minority tracts is the evidence after a notice that cites 'other' as the principal reason 40% of the time. Second-review underwriter has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data close using appraisal-gap outcomes in majority-minority tracts.

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 appraisal-gap outcomes in majority-minority tracts after a notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• Appraisal-gap outcomes in majority-minority tracts reads as Remove access or reverse the item once a notice that cites 'other' as the principal reason 40% of the time is lined up to the same Fair Lending population.
• Appraisal-gap outcomes in majority-minority tracts is closer to Temporary compensating control after a notice that cites 'other' as the principal reason 40% of the time; Remove access or reverse the item would over-claim this Redlining and HMDA Data extract.
• Approve a documented exception is still live in appraisal-gap outcomes in majority-minority tracts for second-review underwriter in a small-business desk using a new vendor score.
• Appraisal-gap outcomes in majority-minority tracts is missing the fact second-review underwriter needs after a notice that cites 'other' as the principal reason 40% of the time; stop this Fair Lending close.

Analysis required

• 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 appraisal-gap outcomes in majority-minority tracts.
• Check HMDA coding and underwriting policy against comparative files show second-review.
• For this Fair Lending Redlining and HMDA Data file, read appraisal-gap outcomes in majority-minority tracts against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move comparative files show second-review for second-review underwriter.

Recommendation