Assess whether dealer overlays introduce prohibited steering (3a54cc)

Situation

In a credit-card issuer changing line-assignment logic, adverse-action notice principal-reason sample is the evidence after a DOJ or CFPB monitor request for pricing files. HMDA data-quality manager 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

HMDA data-quality manager in a credit-card issuer changing line-assignment logic 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 DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• Adverse-action notice principal-reason sample reads as Remove access or reverse the item once a DOJ or CFPB monitor request for pricing files is lined up to the same Fair Lending population.
• Adverse-action notice principal-reason sample is closer to Temporary compensating control after a DOJ or CFPB monitor request for pricing files; 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 HMDA data-quality manager in a credit-card issuer changing line-assignment logic.
• Adverse-action notice principal-reason sample is missing the fact HMDA data-quality manager needs after a DOJ or CFPB monitor request for pricing files; stop this Fair Lending close.

Analysis required

• Flag any disparate-impact table HMDA data-quality manager cannot explain from adverse-action notice principal-reason sample.
• Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend.
• Match the adverse-action language to the facts in adverse-action notice principal-reason sample.
• For this Fair Lending Redlining and HMDA Data file, read adverse-action notice principal-reason sample against a DOJ or CFPB monitor request for pricing files 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 / Redlining and HMDA Data packet (adverse-action notice principal-reason sample after a DOJ or CFPB monitor request for pricing files). Lead with the Fair Lending option adverse-action notice principal-reason sample can support after a DOJ or CFPB monitor request for pricing files, then the two facts that force it, then the Monday action for HMDA data-quality manager in a credit-card issuer changing line-assignment logic.