Assess whether comparative files show second-review bias (483c97)

Situation

In an institution preparing for a redlining exam, small-business decline comparative file set is the evidence after a branch that stopped taking applications in one ZIP. Fair-lending officer has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices close using small-business decline comparative file set.

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 small-business decline comparative file set after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• Fair-lending officer can defend Remove access or reverse the item from small-business decline comparative file set after a branch that stopped taking applications in one ZIP in a Fair Lending challenge.
• Fair-lending officer cannot defend Remove access or reverse the item from small-business decline comparative file set; Temporary compensating control is what the extract actually supports after a branch that stopped taking applications in one ZIP.
• A branch that stopped taking applications in one ZIP never reached the population in small-business decline comparative file set — reopen intake, do not close comparative files show second-review.
• Two facts in small-business decline comparative file set after a branch that stopped taking applications in one ZIP conflict for fair-lending officer; hold this Examination and Notices file.

Analysis required

• Flag any disparate-impact table fair-lending officer cannot explain from small-business decline comparative file set.
• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• Match the adverse-action language to the facts in small-business decline comparative file set.
• For this Fair Lending Examination and Notices file, read small-business decline comparative file set against a branch that stopped taking applications in one ZIP and write the one fact that would move comparative files show second-review for fair-lending officer.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (small-business decline comparative file set after a branch that stopped taking applications in one ZIP). The follow-on Examination and Notices action is what fair-lending officer does next: implement the option, assign an owner, and log the missing fact.