Assess whether dealer overlays introduce prohibited steering (a3e7f1)

Situation

A bank with thin HMDA LAR quality cannot treat an exception rate twice as high for one group after credit controls as color commentary on geographic application and origination heat map. Exam-response coordinator must close dealer overlays introduce prohibited from that extract under Fair Lending / Redlining and HMDA Data.

Decision

Exam-response coordinator 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 geographic application and origination heat map after an exception rate twice as high for one group after credit controls.

Hypotheses to test

• Geographic application and origination heat map reads as Remove access or reverse the item once an exception rate twice as high for one group after credit controls is lined up to the same Fair Lending population.
• Geographic application and origination heat map is closer to Temporary compensating control after an exception rate twice as high for one group after credit controls; Remove access or reverse the item would over-claim this Redlining and HMDA Data extract.
• Approve a documented exception is still live in geographic application and origination heat map for exam-response coordinator in a bank with thin HMDA LAR quality.
• Geographic application and origination heat map is missing the fact exam-response coordinator needs after an exception rate twice as high for one group after credit controls; stop this Fair Lending close.

Analysis required

• Flag any disparate-impact table exam-response coordinator cannot explain from geographic application and origination heat map.
• 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 geographic application and origination heat map.
• For this Fair Lending Redlining and HMDA Data file, read geographic application and origination heat map 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 exam-response coordinator.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (geographic application and origination heat map after an exception rate twice as high for one group after credit controls). Lead with the Fair Lending option geographic application and origination heat map can support after an exception rate twice as high for one group after credit controls, then the two facts that force it, then the Monday action for exam-response coordinator in a bank with thin HMDA LAR quality.