Assess whether comparative files show second-review bias (9eb4f8)

Situation

CRA assessment-area versus lending footprint arrived with a vendor score change with no disparate-impact test for exam-response coordinator. That is a Fair Lending Examination and Notices decision on comparative files show second-review in a mortgage company after a pricing-regression spike.

Decision

Exam-response coordinator 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 CRA assessment-area versus lending footprint after a vendor score change with no disparate-impact test.

Hypotheses to test

• A vendor score change with no disparate-impact test is noise around an already-controlled Examination and Notices process in a mortgage company after a pricing-regression spike, given CRA assessment-area versus lending footprint.
• A vendor score change with no disparate-impact test is the event in CRA assessment-area versus lending footprint that forces Remove access or reverse the item for exam-response coordinator under Fair Lending.
• CRA assessment-area versus lending footprint shows a one-file miss after a vendor score change with no disparate-impact test, not a Examination and Notices program failure.
• CRA assessment-area versus lending footprint cannot decide comparative files show second-review yet after a vendor score change with no disparate-impact test; hold is the only Fair Lending close a mortgage company after a pricing-regression spike can defend.

Analysis required

• Compare CRA assessment-area versus lending footprint 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 exam-response coordinator cannot explain from CRA assessment-area versus lending footprint.
• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• For this Fair Lending Examination and Notices file, read CRA assessment-area versus lending footprint against a vendor score change with no disparate-impact test and write the one fact that would move comparative files show second-review for exam-response coordinator.

Recommendation