Assess whether comparative files show second-review bias (8b8a29)

Situation

An exception rate twice as high for one group after credit controls put small-business decline comparative file set in front of HMDA data-quality manager in a small-business desk using a new vendor score. This Fair Lending / Examination and Notices close is comparative files show second-review from small-business decline comparative file set, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

HMDA data-quality manager in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using small-business decline comparative file set after an exception rate twice as high for one group after credit controls.

Hypotheses to test

• Authorize Remove access or reverse the item now; small-business decline comparative file set already has the discriminator after an exception rate twice as high for one group after credit controls.
• Keep Temporary compensating control in force until small-business decline comparative file set is completed after an exception rate twice as high for one group after credit controls for HMDA data-quality manager.
• Treat small-business decline comparative file set as Approve a documented exception because both readings appear after an exception rate twice as high for one group after credit controls.
• Refuse a Fair Lending close: HMDA data-quality manager does not have the page comparative files show second-review turns on in small-business decline comparative file set.

Analysis required

• Compare small-business decline comparative file set 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 HMDA data-quality manager cannot explain from small-business decline comparative file set.
• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• For this Fair Lending Examination and Notices file, read small-business decline comparative file set 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 HMDA data-quality manager.