Assess whether dealer overlays introduce prohibited steering (b4a9e1)

Situation

The desk packet is mortgage pricing residual by prohibited-basis group after a HMDA resubmission that still fails quality edits. HMDA data-quality manager in a small-business desk using a new vendor score has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices file.

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 mortgage pricing residual by prohibited-basis group after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• HMDA data-quality manager can defend Remove access or reverse the item from mortgage pricing residual by prohibited-basis group after a HMDA resubmission that still fails quality edits in a Fair Lending challenge.
• HMDA data-quality manager cannot defend Remove access or reverse the item from mortgage pricing residual by prohibited-basis group; Temporary compensating control is what the extract actually supports after a HMDA resubmission that still fails quality edits.
• A HMDA resubmission that still fails quality edits never reached the population in mortgage pricing residual by prohibited-basis group — reopen intake, do not close dealer overlays introduce prohibited.
• Two facts in mortgage pricing residual by prohibited-basis group after a HMDA resubmission that still fails quality edits conflict for HMDA data-quality manager; hold this Examination and Notices file.

Analysis required

• Flag any disparate-impact table HMDA data-quality manager cannot explain from mortgage pricing residual by prohibited-basis group.
• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group.
• For this Fair Lending Examination and Notices file, read mortgage pricing residual by prohibited-basis group against a HMDA resubmission that still fails quality edits and write the one fact that would move dealer overlays introduce prohibited for HMDA data-quality manager.

Recommendation

HMDA data-quality manager should take Temporary compensating control on dealer overlays introduce prohibited unless mortgage pricing residual by prohibited-basis group after a HMDA resubmission that still fails quality edits already proves Remove access or reverse the item for this Examination and Notices packet in a small-business desk using a new vendor score. Keep Approve a documented exception live only while mortgage pricing residual by prohibited-basis group is missing the page dealer overlays introduce prohibited turns on. The working test on mortgage pricing residual by prohibited-basis group is whether Flag any disparate-impact table HMDA data-quality manager cannot explain from mortgage pri.