Assess whether dealer overlays introduce prohibited steering (7895db)

Situation

In a lender expanding into majority-minority census tracts, adverse-action notice principal-reason sample is the evidence after a marketing mailer that skipped majority-minority tracts. Adverse-action notice operations lead has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data close using adverse-action notice principal-reason sample.

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 adverse-action notice principal-reason sample after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Adverse-action notice principal-reason sample 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.
• Adverse-action notice principal-reason sample 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 Redlining and HMDA Data extract.
• Approve a documented exception is still live in adverse-action notice principal-reason sample for adverse-action notice operations lead in a lender expanding into majority-minority census tracts.
• Adverse-action notice principal-reason sample 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

• Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts.
• Flag any disparate-impact table adverse-action notice operations lead cannot explain from adverse-action notice principal-reason sample.
• Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend.
• For this Fair Lending Redlining and HMDA Data file, read adverse-action notice principal-reason sample 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.