Assess whether dealer overlays introduce prohibited steering (ca7fe0)

Situation

A lender expanding into majority-minority census tracts cannot treat an exception rate twice as high for one group after credit controls as color commentary on mortgage pricing residual by prohibited-basis group. Adverse-action notice operations lead must close dealer overlays introduce prohibited from that extract under Fair Lending / Redlining and HMDA Data.

Decision

Adverse-action notice operations lead in a lender expanding into majority-minority census tracts must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using mortgage pricing residual by prohibited-basis group after an exception rate twice as high for one group after credit controls.

Hypotheses to test

• Adverse-action notice operations lead can defend Remove access or reverse the item from mortgage pricing residual by prohibited-basis group after an exception rate twice as high for one group after credit controls in a Fair Lending challenge.
• Adverse-action notice operations lead cannot defend Remove access or reverse the item from mortgage pricing residual by prohibited-basis group; Temporary compensating control is what the extract actually supports after an exception rate twice as high for one group after credit controls.
• An exception rate twice as high for one group after credit controls never reached the population in mortgage pricing residual by prohibited-basis group — reopen intake, do not close dealer overlays introduce prohibited.
• Two facts in mortgage pricing residual by prohibited-basis group after an exception rate twice as high for one group after credit controls conflict for adverse-action notice operations lead; hold this Redlining and HMDA Data file.

Analysis required

• Flag any disparate-impact table adverse-action notice operations lead cannot explain from mortgage pricing residual by prohibited-basis group.
• Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend.
• Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group.
• For this Fair Lending Redlining and HMDA Data file, read mortgage pricing residual by prohibited-basis group against an exception rate twice as high for one group after credit controls and write the one fact that would move dealer overlays introduce prohibited for adverse-action notice operations lead.