Assess whether comparative files show second-review bias (545c4e)

Situation

In a small-business desk using a new vendor score, underwriting exception log by branch is the evidence after a marketing mailer that skipped majority-minority tracts. Second-review underwriter has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data close using underwriting exception log by branch.

Decision

Second-review underwriter 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 underwriting exception log by branch after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Authorize Remove access or reverse the item now; underwriting exception log by branch already has the discriminator after a marketing mailer that skipped majority-minority tracts.
• Keep Temporary compensating control in force until underwriting exception log by branch is completed after a marketing mailer that skipped majority-minority tracts for second-review underwriter.
• Treat underwriting exception log by branch as Approve a documented exception because both readings appear after a marketing mailer that skipped majority-minority tracts.
• Refuse a Fair Lending close: second-review underwriter does not have the page comparative files show second-review turns on in underwriting exception log by branch.

Analysis required

• Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts.
• Flag any disparate-impact table second-review underwriter cannot explain from underwriting exception log by branch.
• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• For this Fair Lending Redlining and HMDA Data file, read underwriting exception log by branch against a marketing mailer that skipped majority-minority tracts and write the one fact that would move comparative files show second-review for second-review underwriter.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (underwriting exception log by branch after a marketing mailer that skipped majority-minority tracts). The follow-on Redlining and HMDA Data action is what second-review underwriter does next: implement the option, assign an owner, and log the missing fact.