Community-development lender must resolve whether dealer overlays introduce

Situation

In a bank with thin HMDA LAR quality, adverse-action notice principal-reason sample is the evidence after a vendor score change with no disparate-impact test. Community-development lender has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits close using adverse-action notice principal-reason sample.

Decision

Community-development lender in a bank with thin HMDA LAR quality 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 vendor score change with no disparate-impact test.

Hypotheses to test

• Community-development lender can defend Remove access or reverse the item from adverse-action notice principal-reason sample after a vendor score change with no disparate-impact test in a Fair Lending challenge.
• Community-development lender 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 a vendor score change with no disparate-impact test.
• A vendor score change with no disparate-impact test 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 a vendor score change with no disparate-impact test conflict for community-development lender; hold this Pricing and Credit Limits file.

Analysis required

• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• Match the adverse-action language to the facts in adverse-action notice principal-reason sample.
• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• For this Fair Lending Pricing and Credit Limits file, read adverse-action notice principal-reason sample against a vendor score change with no disparate-impact test and write the one fact that would move dealer overlays introduce prohibited for community-development lender.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (adverse-action notice principal-reason sample after a vendor score change with no disparate-impact test). The follow-on Pricing and Credit Limits action is what community-development lender does next: implement the option, assign an owner, and log the missing fact.