Assess whether dealer overlays introduce prohibited steering (e76e59)

Situation

Adverse-action notice operations lead in a credit-card issuer changing line-assignment logic has one working extract — mortgage pricing residual by prohibited-basis group — after a community complaint about appraisal gaps. If mortgage pricing residual by prohibited-basis group cannot support dealer overlays introduce prohibited, the honest Fair Lending output is hold.

Decision

Adverse-action notice operations lead 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 mortgage pricing residual by prohibited-basis group after a community complaint about appraisal gaps.

Hypotheses to test

• Mortgage pricing residual by prohibited-basis group reads as Remove access or reverse the item once a community complaint about appraisal gaps is lined up to the same Fair Lending population.
• Mortgage pricing residual by prohibited-basis group is closer to Temporary compensating control after a community complaint about appraisal gaps; Remove access or reverse the item would over-claim this Examination and Notices extract.
• Approve a documented exception is still live in mortgage pricing residual by prohibited-basis group for adverse-action notice operations lead in a credit-card issuer changing line-assignment logic.
• Mortgage pricing residual by prohibited-basis group is missing the fact adverse-action notice operations lead needs after a community complaint about appraisal gaps; stop this Fair Lending close.

Analysis required

• Flag any disparate-impact table adverse-action notice operations lead cannot explain from mortgage pricing residual by prohibited-basis group.
• 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 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 community complaint about appraisal gaps and write the one fact that would move dealer overlays introduce prohibited for adverse-action notice operations lead.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (mortgage pricing residual by prohibited-basis group after a community complaint about appraisal gaps). If mortgage pricing residual by prohibited-basis group cannot force a Fair Lending label under Examination and Notices, stop. If mortgage pricing residual by prohibited-basis group after a community complaint about appraisal gaps cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Examination and Notices close, adverse-action notice operations lead must do not infer a control or scheme beyond the transaction and entitlement evidence.