Assess whether comparative files show second-review bias (6ef0f7)

Situation

The CRA and Special-Purpose Programs desk packet is adverse-action notice principal-reason sample after a CRA PE that called the assessment area too narrow. CRA strategist in a mortgage company after a pricing-regression spike must name Remove access or reverse the item or Temporary compensating control for this Fair Lending file. CRA strategist in a mortgage company after a pricing-regression spike has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs file.

Decision

CRA strategist in a mortgage company after a pricing-regression spike must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using adverse-action notice principal-reason sample after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• A CRA PE that called the assessment area too narrow is noise around an already-controlled CRA and Special-Purpose Programs process in a mortgage company after a pricing-regression spike, given adverse-action notice principal-reason sample.
• A CRA PE that called the assessment area too narrow is the event in adverse-action notice principal-reason sample that forces Remove access or reverse the item for CRA strategist under Fair Lending.
• Adverse-action notice principal-reason sample shows a one-file miss after a CRA PE that called the assessment area too narrow, not a CRA and Special-Purpose Programs program failure.
• Adverse-action notice principal-reason sample cannot decide comparative files show second-review yet after a CRA PE that called the assessment area too narrow; hold is the only Fair Lending close a mortgage company after a pricing-regression spike can defend.

Analysis required

• Flag any disparate-impact table CRA strategist cannot explain from adverse-action notice principal-reason sample.
• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• Match the adverse-action language to the facts in adverse-action notice principal-reason sample.
• For this Fair Lending CRA and Special-Purpose Programs file, read adverse-action notice principal-reason sample against a CRA PE that called the assessment area too narrow and write the one fact that would move comparative files show second-review for CRA strategist.