Assess whether comparative files show second-review bias (764c56)

Situation

CRA and Special-Purpose Programs work in a bank with thin HMDA LAR quality now turns on comparative files show second-review because a community complaint about appraisal gaps put model-reason-code mapping that does not match notices in play. CRA and Special-Purpose Programs work in a bank with thin HMDA LAR quality now turns on comparative files show second-review because a community complaint about appraisal gaps put model-reason-code mapping that does not match notices in play; fair-lending officer should say what model-reason-code mapping that does not match notices proves for Fair Lending.

Decision

Fair-lending officer in a bank with thin HMDA LAR quality 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 community complaint about appraisal gaps.

Hypotheses to test

• The population in model-reason-code mapping that does not match notices is the one a community complaint about appraisal gaps named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file.
• The population in model-reason-code mapping that does not match notices is adjacent only to a community complaint about appraisal gaps; Temporary compensating control is the honest Fair Lending call.
• A bank with thin HMDA LAR quality already contained a community complaint about appraisal gaps before model-reason-code mapping that does not match notices arrived; no new CRA and Special-Purpose Programs path.
• Provenance on model-reason-code mapping that does not match notices after a community complaint about appraisal gaps is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• 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 community complaint about appraisal gaps.
• Flag any disparate-impact table fair-lending officer cannot explain from model-reason-code mapping that does not match notices.
• For this Fair Lending CRA and Special-Purpose Programs file, read model-reason-code mapping that does not match notices against a community complaint about appraisal gaps and write the one fact that would move comparative files show second-review for fair-lending officer.