Assess whether comparative files show second-review bias (526e5b)

Situation

Adverse-action notice principal-reason sample arrived with a vendor score change with no disparate-impact test for CRA strategist. That is a Fair Lending Redlining and HMDA Data decision on comparative files show second-review in an institution preparing for a redlining exam.

Decision

CRA strategist in an institution preparing for a redlining exam 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 vendor score change with no disparate-impact test.

Hypotheses to test

• The population in adverse-action notice principal-reason sample is the one a vendor score change with no disparate-impact test named, so Remove access or reverse the item follows for this Redlining and HMDA Data file.
• The population in adverse-action notice principal-reason sample is adjacent only to a vendor score change with no disparate-impact test; Temporary compensating control is the honest Fair Lending call.
• An institution preparing for a redlining exam already contained a vendor score change with no disparate-impact test before adverse-action notice principal-reason sample arrived; no new Redlining and HMDA Data path.
• Provenance on adverse-action notice principal-reason sample after a vendor score change with no disparate-impact test is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Check HMDA coding and underwriting policy against comparative files show second-review.
• Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test.
• Flag any disparate-impact table CRA strategist cannot explain from adverse-action notice principal-reason sample.
• For this Fair Lending Redlining and HMDA Data file, read adverse-action notice principal-reason sample against a vendor score change with no disparate-impact test and write the one fact that would move comparative files show second-review for CRA strategist.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (adverse-action notice principal-reason sample after a vendor score change with no disparate-impact test). If adverse-action notice principal-reason sample cannot force a Fair Lending label under Redlining and HMDA Data, stop. If adverse-action notice principal-reason sample after a vendor score change with no disparate-impact test cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Redlining and HMDA Data close, CRA strategist must do not infer a control or scheme beyond the transaction and entitlement evidence.