Assess whether dealer overlays introduce prohibited steering (d7d3c6)

Situation

After an exception rate twice as high for one group after credit controls, adverse-action notice principal-reason sample is what adverse-action notice operations lead can touch in a small-business desk using a new vendor score. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this CRA and Special-Purpose Programs file.

Decision

Adverse-action notice operations lead in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using adverse-action notice principal-reason sample 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 adverse-action notice principal-reason sample 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 adverse-action notice principal-reason sample; 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 adverse-action notice principal-reason sample — reopen intake, do not close dealer overlays introduce prohibited.
• Two facts in adverse-action notice principal-reason sample after an exception rate twice as high for one group after credit controls conflict for adverse-action notice operations lead; hold this CRA and Special-Purpose Programs file.

Analysis required

• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls.
• Flag any disparate-impact table adverse-action notice operations lead cannot explain from adverse-action notice principal-reason sample.
• For this Fair Lending CRA and Special-Purpose Programs file, read adverse-action notice principal-reason sample 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.