Assess whether dealer overlays introduce prohibited steering (989ea4)

Situation

The CRA and Special-Purpose Programs desk packet is CRA assessment-area versus lending footprint after an underwriter chat that used coded language. Model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic must name Remove access or reverse the item or Temporary compensating control for this Fair Lending file. Model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs file.

Decision

Model-risk partner for credit scoring 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 CRA assessment-area versus lending footprint after an underwriter chat that used coded language.

Hypotheses to test

• The population in CRA assessment-area versus lending footprint is the one an underwriter chat that used coded language named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file.
• The population in CRA assessment-area versus lending footprint is adjacent only to an underwriter chat that used coded language; Temporary compensating control is the honest Fair Lending call.
• A credit-card issuer changing line-assignment logic already contained an underwriter chat that used coded language before CRA assessment-area versus lending footprint arrived; no new CRA and Special-Purpose Programs path.
• Provenance on CRA assessment-area versus lending footprint after an underwriter chat that used coded language is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language.
• Flag any disparate-impact table model-risk partner for credit scoring cannot explain from CRA assessment-area versus lending footprint.
• For this Fair Lending CRA and Special-Purpose Programs file, read CRA assessment-area versus lending footprint against an underwriter chat that used coded language and write the one fact that would move dealer overlays introduce prohibited for model-risk partner for credit scoring.