Assess whether a redlining pattern exists after controls (7a15df)

Situation

A redlining pattern exists sits with fair-lending officer because a vendor score change with no disparate-impact test hit an institution preparing for a redlining exam. Evidence is model-reason-code mapping that does not match notices; write the Fair Lending Examination and Notices option that extract can carry.

Decision

Fair-lending officer in an institution preparing for a redlining exam 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 vendor score change with no disparate-impact test.

Hypotheses to test

• Fair-lending officer can defend Remove access or reverse the item from model-reason-code mapping that does not match notices after a vendor score change with no disparate-impact test in a Fair Lending challenge.
• Fair-lending officer cannot defend Remove access or reverse the item from model-reason-code mapping that does not match notices; Temporary compensating control is what the extract actually supports after a vendor score change with no disparate-impact test.
• A vendor score change with no disparate-impact test never reached the population in model-reason-code mapping that does not match notices — reopen intake, do not close a redlining pattern exists.
• Two facts in model-reason-code mapping that does not match notices after a vendor score change with no disparate-impact test conflict for fair-lending officer; hold this Examination and Notices file.

Analysis required

• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• Match the adverse-action language to the facts in model-reason-code mapping that does not match notices.
• Check HMDA coding and underwriting policy against a redlining pattern exists.
• For this Fair Lending Examination and Notices file, read model-reason-code mapping that does not match notices against a vendor score change with no disparate-impact test and write the one fact that would move a redlining pattern exists for fair-lending officer.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (model-reason-code mapping that does not match notices after a vendor score change with no disparate-impact test). Lead with the Fair Lending option model-reason-code mapping that does not match notices can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for fair-lending officer in an institution preparing for a redlining exam.