Assess whether dealer overlays introduce prohibited steering after a board

SITUATION A lender expanding into majority-minority census tracts cannot treat a board asking if the bank should settle a matched-pair study as incidental context on model-reason-code mapping that does not match notices. HMDA data-quality manager must close dealer overlays introduce prohibited from that extract under Fair Lending / Pricing and Credit Limits.

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 model-reason-code mapping that does not match notices after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. Model-reason-code mapping that does not match notices reads as Remove access or reverse the item once a board asking if the bank should settle a matched-pair study is lined up to the same Fair Lending population. 2. Model-reason-code mapping that does not match notices is closer to Temporary compensating control after a board asking if the bank should settle a matched-pair study; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract. 3. Approve a documented exception is still live in model-reason-code mapping that does not match notices for HMDA data-quality manager in a lender expanding into majority-minority census tracts. 4. Model-reason-code mapping that does not match notices is missing the fact HMDA data-quality manager needs after a board asking if the bank should settle a matched-pair study; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against dealer overlays introduce prohibited. 2. Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study. 3. Flag any disparate-impact table HMDA data-quality manager cannot explain from model-reason-code mapping that does not match notices. 4. For this Fair Lending Pricing and Credit Limits file, read model-reason-code mapping that does not match notices against a board asking if the bank should settle a matched-pair study 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 (model-reason-code mapping that does not match notices after a board asking if the bank should settle a matched-pair study). Lead with the Fair Lending option model-reason-code mapping that does not match notices can support after a board asking if the bank should settle a matched-pair study, then the two facts that force it, then the Monday action for HMDA data-quality manager in a lender expanding into majority-minority census tracts.