Assess whether dealer overlays introduce prohibited steering (5fd157)

Situation

A credit-card issuer changing line-assignment logic cannot treat a marketing mailer that skipped majority-minority tracts as color commentary on SPCP written plan versus actual originations. Adverse-action notice operations lead must close dealer overlays introduce prohibited from that extract under Fair Lending / Examination and Notices.

Decision

Adverse-action notice operations lead in a credit-card issuer changing line-assignment logic 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 marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• SPCP written plan versus actual originations reads as Remove access or reverse the item once a marketing mailer that skipped majority-minority tracts is lined up to the same Fair Lending population.
• SPCP written plan versus actual originations is closer to Temporary compensating control after a marketing mailer that skipped majority-minority tracts; Remove access or reverse the item would over-claim this Examination and Notices extract.
• Approve a documented exception is still live in SPCP written plan versus actual originations for adverse-action notice operations lead in a credit-card issuer changing line-assignment logic.
• SPCP written plan versus actual originations is missing the fact adverse-action notice operations lead needs after a marketing mailer that skipped majority-minority tracts; stop this Fair Lending close.

Analysis required

• Match the adverse-action language to the facts in SPCP written plan versus actual originations.
• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts.
• For this Fair Lending Examination and Notices file, read SPCP written plan versus actual originations against a marketing mailer that skipped majority-minority tracts and write the one fact that would move dealer overlays introduce prohibited for adverse-action notice operations lead.

Recommendation