Assess whether comparative files show second-review bias (608713)

Situation

Comparative files show second-review sits with HMDA data-quality manager because an underwriter chat that used coded language hit a credit-card issuer changing line-assignment logic. Evidence is CRA assessment-area versus lending footprint; write the Fair Lending Redlining and HMDA Data option that extract can carry.

Decision

HMDA data-quality manager in a credit-card issuer changing line-assignment logic must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using CRA assessment-area versus lending footprint after an underwriter chat that used coded language.

Hypotheses to test

• HMDA data-quality manager can defend Remove access or reverse the item from CRA assessment-area versus lending footprint after an underwriter chat that used coded language in a Fair Lending challenge.
• HMDA data-quality manager cannot defend Remove access or reverse the item from CRA assessment-area versus lending footprint; Temporary compensating control is what the extract actually supports after an underwriter chat that used coded language.
• An underwriter chat that used coded language never reached the population in CRA assessment-area versus lending footprint — reopen intake, do not close comparative files show second-review.
• Two facts in CRA assessment-area versus lending footprint after an underwriter chat that used coded language conflict for HMDA data-quality manager; hold this Redlining and HMDA Data file.

Analysis required

• Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language.
• Flag any disparate-impact table HMDA data-quality manager cannot explain from CRA assessment-area versus lending footprint.
• Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend.
• For this Fair Lending Redlining and HMDA Data file, read CRA assessment-area versus lending footprint against an underwriter chat that used coded language and write the one fact that would move comparative files show second-review for HMDA data-quality manager.

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 (CRA assessment-area versus lending footprint after an underwriter chat that used coded language). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after an underwriter chat that used coded language, then the two facts that force it, then the Monday action for HMDA data-quality manager in a credit-card issuer changing line-assignment logic.