Assess whether comparative files show second-review bias (df553c)

Situation

Model-risk partner for credit scoring owns comparative files show second-review inside a lender expanding into majority-minority census tracts with adverse-action notice principal-reason sample as the only packet. A marketing mailer that skipped majority-minority tracts is what changed the clock for this Fair Lending Examination and Notices file.

Decision

Model-risk partner for credit scoring in a lender expanding into majority-minority census tracts 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 marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• A marketing mailer that skipped majority-minority tracts is noise around an already-controlled Examination and Notices process in a lender expanding into majority-minority census tracts, given adverse-action notice principal-reason sample.
• A marketing mailer that skipped majority-minority tracts is the event in adverse-action notice principal-reason sample that forces Remove access or reverse the item for model-risk partner for credit scoring under Fair Lending.
• Adverse-action notice principal-reason sample shows a one-file miss after a marketing mailer that skipped majority-minority tracts, not a Examination and Notices program failure.
• Adverse-action notice principal-reason sample cannot decide comparative files show second-review yet after a marketing mailer that skipped majority-minority tracts; hold is the only Fair Lending close a lender expanding into majority-minority census tracts can defend.

Analysis required

• Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend.
• Match the adverse-action language to the facts in adverse-action notice principal-reason sample.
• Check HMDA coding and underwriting policy against comparative files show second-review.
• For this Fair Lending Examination and Notices file, read adverse-action notice principal-reason sample against a marketing mailer that skipped majority-minority tracts and write the one fact that would move comparative files show second-review for model-risk partner for credit scoring.

Recommendation