Assess whether a redlining pattern exists after controls (5bb1de)

Situation

Model-reason-code mapping that does not match notices arrived with a SPCP that originated almost no loans to the intended class for second-review underwriter. That is a Fair Lending Redlining and HMDA Data decision on a redlining pattern exists in a small-business desk using a new vendor score.

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 model-reason-code mapping that does not match notices after a SPCP that originated almost no loans to the intended class.

Hypotheses to test

• A SPCP that originated almost no loans to the intended class is noise around an already-controlled Redlining and HMDA Data process in a small-business desk using a new vendor score, given model-reason-code mapping that does not match notices.
• A SPCP that originated almost no loans to the intended class is the event in model-reason-code mapping that does not match notices that forces Remove access or reverse the item for second-review underwriter under Fair Lending.
• Model-reason-code mapping that does not match notices shows a one-file miss after a SPCP that originated almost no loans to the intended class, not a Redlining and HMDA Data program failure.
• Model-reason-code mapping that does not match notices cannot decide a redlining pattern exists yet after a SPCP that originated almost no loans to the intended class; hold is the only Fair Lending close a small-business desk using a new vendor score can defend.

Analysis required

• Check HMDA coding and underwriting policy against a redlining pattern exists.
• Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class.
• Flag any disparate-impact table second-review underwriter cannot explain from model-reason-code mapping that does not match notices.
• For this Fair Lending Redlining and HMDA Data file, read model-reason-code mapping that does not match notices against a SPCP that originated almost no loans to the intended class and write the one fact that would move a redlining pattern exists for second-review underwriter.

Recommendation