Assess whether comparative files show second-review bias (56593c)

Situation

In a lender expanding into majority-minority census tracts, model-reason-code mapping that does not match notices is the evidence after a DOJ or CFPB monitor request for pricing files. Adverse-action notice operations lead has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data close using model-reason-code mapping that does not match notices.

Decision

Adverse-action notice operations lead 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 model-reason-code mapping that does not match notices after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• Adverse-action notice operations lead can defend Remove access or reverse the item from model-reason-code mapping that does not match notices after a DOJ or CFPB monitor request for pricing files in a Fair Lending challenge.
• Adverse-action notice operations lead cannot defend Remove access or reverse the item from model-reason-code mapping that does not match notices; Temporary compensating control is what the extract actually supports after a DOJ or CFPB monitor request for pricing files.
• A DOJ or CFPB monitor request for pricing files never reached the population in model-reason-code mapping that does not match notices — reopen intake, do not close comparative files show second-review.
• Two facts in model-reason-code mapping that does not match notices after a DOJ or CFPB monitor request for pricing files conflict for adverse-action notice operations lead; hold this Redlining and HMDA Data file.

Analysis required

• Flag any disparate-impact table adverse-action notice operations lead cannot explain from model-reason-code mapping that does not match notices.
• 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 model-reason-code mapping that does not match notices.
• For this Fair Lending Redlining and HMDA Data file, read model-reason-code mapping that does not match notices against a DOJ or CFPB monitor request for pricing files and write the one fact that would move comparative files show second-review for adverse-action notice operations lead.