Assess whether comparative files show second-review bias (97e324)

Situation

A notice that cites 'other' as the principal reason 40% of the time put CRA assessment-area versus lending footprint in front of adverse-action notice operations lead in a small-business desk using a new vendor score. This Fair Lending / CRA and Special-Purpose Programs close is comparative files show second-review from CRA assessment-area versus lending footprint, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

Adverse-action notice operations lead 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 CRA assessment-area versus lending footprint after a notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• A notice that cites 'other' as the principal reason 40% of the time is noise around an already-controlled CRA and Special-Purpose Programs process in a small-business desk using a new vendor score, given CRA assessment-area versus lending footprint.
• A notice that cites 'other' as the principal reason 40% of the time is the event in CRA assessment-area versus lending footprint that forces Remove access or reverse the item for adverse-action notice operations lead under Fair Lending.
• CRA assessment-area versus lending footprint shows a one-file miss after a notice that cites 'other' as the principal reason 40% of the time, not a CRA and Special-Purpose Programs program failure.
• CRA assessment-area versus lending footprint cannot decide comparative files show second-review yet after a notice that cites 'other' as the principal reason 40% of the time; hold is the only Fair Lending close a small-business desk using a new vendor score can defend.

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 CRA assessment-area versus lending footprint.
• Check HMDA coding and underwriting policy against comparative files show second-review.
• For this Fair Lending CRA and Special-Purpose Programs file, read CRA assessment-area versus lending footprint 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 adverse-action notice operations lead.