Assess whether comparative files show second-review bias (a62524)

Situation

Model-reason-code mapping that does not match notices arrived with a marketing mailer that skipped majority-minority tracts for community-development lender. That is a Fair Lending Redlining and HMDA Data decision on comparative files show second-review in a mortgage company after a pricing-regression spike.

Decision

Community-development lender 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 model-reason-code mapping that does not match notices after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Community-development lender can defend Remove access or reverse the item from model-reason-code mapping that does not match notices after a marketing mailer that skipped majority-minority tracts in a Fair Lending challenge.
• Community-development lender 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 marketing mailer that skipped majority-minority tracts.
• A marketing mailer that skipped majority-minority tracts 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 marketing mailer that skipped majority-minority tracts conflict for community-development lender; hold this Redlining and HMDA Data file.

Analysis required

• Match the adverse-action language to the facts in model-reason-code mapping that does not match notices.
• Check HMDA coding and underwriting policy against comparative files show second-review.
• Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts.
• For this Fair Lending Redlining and HMDA Data file, read model-reason-code mapping that does not match notices against a marketing mailer that skipped majority-minority tracts and write the one fact that would move comparative files show second-review for community-development lender.

Recommendation