Assess whether a redlining pattern exists after controls from adverse-action

Situation

A branch that stopped taking applications in one ZIP put adverse-action notice principal-reason sample in front of fair-lending officer in a mortgage company after a pricing-regression spike. This Fair Lending / Pricing and Credit Limits close is a redlining pattern exists from adverse-action notice principal-reason sample, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

Fair-lending officer in a mortgage company after a pricing-regression spike must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using adverse-action notice principal-reason sample 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 adverse-action notice principal-reason sample 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 adverse-action notice principal-reason sample; 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 adverse-action notice principal-reason sample — reopen intake, do not close a redlining pattern exists.
• Two facts in adverse-action notice principal-reason sample after a branch that stopped taking applications in one ZIP conflict for fair-lending officer; hold this Pricing and Credit Limits file.

Analysis required

• Flag any disparate-impact table fair-lending officer cannot explain from adverse-action notice principal-reason sample.
• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• Match the adverse-action language to the facts in adverse-action notice principal-reason sample.
• For this Fair Lending Pricing and Credit Limits file, read adverse-action notice principal-reason sample against a branch that stopped taking applications in one ZIP and write the one fact that would move a redlining pattern exists for fair-lending officer.

Recommendation