Assess whether dealer overlays introduce prohibited steering (88ed35)

Situation

Dealer overlays introduce prohibited sits with adverse-action notice operations lead because a vendor score change with no disparate-impact test hit a credit-card issuer changing line-assignment logic. Evidence is SPCP written plan versus actual originations; write the Fair Lending Examination and Notices option that extract can carry.

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 vendor score change with no disparate-impact test.

Hypotheses to test

• Adverse-action notice operations lead can defend Remove access or reverse the item from SPCP written plan versus actual originations after a vendor score change with no disparate-impact test in a Fair Lending challenge.
• Adverse-action notice operations lead 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 vendor score change with no disparate-impact test.
• A vendor score change with no disparate-impact test never reached the population in SPCP written plan versus actual originations — reopen intake, do not close dealer overlays introduce prohibited.
• Two facts in SPCP written plan versus actual originations after a vendor score change with no disparate-impact test conflict for adverse-action notice operations lead; hold this Examination and Notices file.

Analysis required

• Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend.
• 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.
• For this Fair Lending Examination and Notices file, read SPCP written plan versus actual originations against a vendor score change with no disparate-impact test and write the one fact that would move dealer overlays introduce prohibited for adverse-action notice operations lead.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (SPCP written plan versus actual originations after a vendor score change with no disparate-impact test). The follow-on Examination and Notices action is what adverse-action notice operations lead does next: implement the option, assign an owner, and log the missing fact.