Assess whether notices match the actual decisioning reasons (20d88e)

SITUATION After a marketing mailer that skipped majority-minority tracts, model-reason-code mapping that does not match notices is what fair-lending officer can touch in a manufactured-housing lender with dealer-originated files. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Redlining and HMDA Data file.

DECISION Fair-lending officer in a manufactured-housing lender with dealer-originated files 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 marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. The population in model-reason-code mapping that does not match notices is the one a marketing mailer that skipped majority-minority tracts named, so Remove access or reverse the item follows for this Redlining and HMDA Data file. 2. The population in model-reason-code mapping that does not match notices is adjacent only to a marketing mailer that skipped majority-minority tracts; Temporary compensating control is the honest Fair Lending call. 3. A manufactured-housing lender with dealer-originated files already contained a marketing mailer that skipped majority-minority tracts before model-reason-code mapping that does not match notices arrived; no new Redlining and HMDA Data path. 4. Provenance on model-reason-code mapping that does not match notices after a marketing mailer that skipped majority-minority tracts is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Flag any disparate-impact table fair-lending officer cannot explain from model-reason-code mapping that does not match notices. 2. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 3. Match the adverse-action language to the facts in model-reason-code mapping that does not match notices. 4. For this Fair Lending Redlining and HMDA Data file, read model-reason-code mapping that does not match notices against a marketing mailer that skipped majority-minority tracts and write the one fact that would move notices match the actual for fair-lending officer.

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 (model-reason-code mapping that does not match notices after a marketing mailer that skipped majority-minority tracts). The follow-on Redlining and HMDA Data action is what fair-lending officer does next: implement the option, assign an owner, and log the missing fact.