Assess whether dealer overlays introduce prohibited steering (9e57a6)

Situation

Credit-card limit assignment disparity table arrived with a branch that stopped taking applications in one ZIP for HMDA data-quality manager. That is a Fair Lending Examination and Notices decision on dealer overlays introduce prohibited in a small-business desk using a new vendor score.

Decision

HMDA data-quality manager 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 credit-card limit assignment disparity table after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• A branch that stopped taking applications in one ZIP is noise around an already-controlled Examination and Notices process in a small-business desk using a new vendor score, given credit-card limit assignment disparity table.
• A branch that stopped taking applications in one ZIP is the event in credit-card limit assignment disparity table that forces Remove access or reverse the item for HMDA data-quality manager under Fair Lending.
• Credit-card limit assignment disparity table shows a one-file miss after a branch that stopped taking applications in one ZIP, not a Examination and Notices program failure.
• Credit-card limit assignment disparity table cannot decide dealer overlays introduce prohibited yet after a branch that stopped taking applications in one ZIP; hold is the only Fair Lending close a small-business desk using a new vendor score can defend.

Analysis required

• Match the adverse-action language to the facts in credit-card limit assignment disparity table.
• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP.
• For this Fair Lending Examination and Notices file, read credit-card limit assignment disparity table against a branch that stopped taking applications in one ZIP 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 / Examination and Notices packet (credit-card limit assignment disparity table after a branch that stopped taking applications in one ZIP). Lead with the Fair Lending option credit-card limit assignment disparity table can support after a branch that stopped taking applications in one ZIP, then the two facts that force it, then the Monday action for HMDA data-quality manager in a small-business desk using a new vendor score.