Assess whether comparative files show second-review bias (e3763a)

Situation

Fair-lending officer in an institution preparing for a redlining exam has one working extract — model-reason-code mapping that does not match notices — after an exception rate twice as high for one group after credit controls. If model-reason-code mapping that does not match notices cannot support comparative files show second-review, the honest Fair Lending output is hold.

Decision

Fair-lending officer in an institution preparing for a redlining exam 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 an exception rate twice as high for one group after credit controls.

Hypotheses to test

• The population named in model-reason-code mapping that does not match notices is the one an exception rate twice as high for one group after credit controls identified, so Remove access or reverse the item follows for this Examination and Notices file.
• The population in model-reason-code mapping that does not match notices is only adjacent to an exception rate twice as high for one group after credit controls; Temporary compensating control is the honest Fair Lending call for fair-lending officer.
• An institution preparing for a redlining exam already contained an exception rate twice as high for one group after credit controls before model-reason-code mapping that does not match notices arrived, so comparative files show second-review is not a new Examination and Notices path.
• Provenance on model-reason-code mapping that does not match notices after an exception rate twice as high for one group after credit controls is broken; do not pick Remove access or reverse the item or Temporary compensating control for comparative files show second-review yet.

Analysis required

• Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls.
• Flag any disparate-impact table fair-lending officer cannot explain from model-reason-code mapping that does not match notices.
• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• For this Fair Lending Examination and Notices file, read model-reason-code mapping that does not match notices against an exception rate twice as high for one group after credit controls and write the one fact that would move comparative files show second-review for fair-lending officer.