Assess whether a redlining pattern exists after controls (3ceff9)

Situation

In a small-business desk using a new vendor score, SPCP written plan versus actual originations is the evidence after a board asking if the bank should settle a matched-pair study. 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 SPCP written plan versus actual originations.

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 SPCP written plan versus actual originations after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• Second-review underwriter can defend Remove access or reverse the item from SPCP written plan versus actual originations after a board asking if the bank should settle a matched-pair study in a Fair Lending challenge.
• Second-review underwriter cannot defend Remove access or reverse the item from SPCP written plan versus actual originations; Temporary compensating control is what the extract actually supports after a board asking if the bank should settle a matched-pair study.
• A board asking if the bank should settle a matched-pair study never reached the population in SPCP written plan versus actual originations — reopen intake, do not close a redlining pattern exists.
• Two facts in SPCP written plan versus actual originations after a board asking if the bank should settle a matched-pair study conflict for second-review underwriter; hold this Redlining and HMDA Data file.

Analysis required

• Flag any disparate-impact table second-review underwriter cannot explain from SPCP written plan versus actual originations.
• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• Match the adverse-action language to the facts in SPCP written plan versus actual originations.
• For this Fair Lending Redlining and HMDA Data file, read SPCP written plan versus actual originations against a board asking if the bank should settle a matched-pair study and write the one fact that would move a redlining pattern exists for second-review underwriter.

Recommendation