When scoping a consumer fair lending audit or review, determining the control group vs protected group(s); do you:
(1) look at the primary applicant/borrower only, or
(2) look at each applicant/borrower individually (i.e. in the case of a joint loan, it would be like looking at two separate loans)?
Any input is appreciated. Thanks.

I guess it might depend on the context of the risk factor that is being evaluated and the amount of information available. If you are evaluating, say mixed race joint applicants, they might even be a separate target group to be evaluated against non-mixed race joint applicants.