Assess whether dealer overlays introduce prohibited steering after a SPCP

SITUATION Geographic application and origination heat map arrived with a SPCP that originated almost no loans to the intended class for HMDA data-quality manager. That is a Fair Lending Pricing and Credit Limits decision on dealer overlays introduce prohibited in a lender expanding into majority-minority census tracts.

DECISION HMDA data-quality manager 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 geographic application and origination heat map after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. HMDA data-quality manager can defend Remove access or reverse the item from geographic application and origination heat map after a SPCP that originated almost no loans to the intended class in a Fair Lending challenge. 2. HMDA data-quality manager cannot defend Remove access or reverse the item from geographic application and origination heat map; Temporary compensating control is what the extract actually supports after a SPCP that originated almost no loans to the intended class. 3. A SPCP that originated almost no loans to the intended class never reached the population in geographic application and origination heat map — reopen intake, do not close dealer overlays introduce prohibited. 4. Two facts in geographic application and origination heat map after a SPCP that originated almost no loans to the intended class conflict for HMDA data-quality manager; hold this Pricing and Credit Limits file.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 2. Match the adverse-action language to the facts in geographic application and origination heat map. 3. Check HMDA coding and underwriting policy against dealer overlays introduce prohibited. 4. For this Fair Lending Pricing and Credit Limits file, read geographic application and origination heat map against a SPCP that originated almost no loans to the intended class and write the one fact that would move dealer overlays introduce prohibited for HMDA data-quality manager.

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 (geographic application and origination heat map after a SPCP that originated almost no loans to the intended class). The follow-on Pricing and Credit Limits action is what HMDA data-quality manager does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on dealer overlays introduce prohibited, then the evidence in geographic application and origination heat map, then the action for HMDA data-quality manager - Hypothesis scorecard against geographic application and origination heat map: supported / rejected / untestable - What changes dealer overlays introduce prohibited if a SPCP that originated almost no loans to the intended class is later withdrawn - Named option among Remove access or reverse the item, Temporary compensating control, Approve a documented exception and the fact that kills the others