Assess whether dealer overlays introduce prohibited steering from geographic

SITUATION A credit union rolling out a special-purpose credit program cannot treat a vendor score change with no disparate-impact test as incidental context on geographic application and origination heat map. Adverse-action notice operations lead must close dealer overlays introduce prohibited from that extract under Fair Lending / Pricing and Credit Limits.

DECISION Adverse-action notice operations lead in a credit union rolling out a special-purpose credit program must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using geographic application and origination heat map after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. Geographic application and origination heat map reads as Remove access or reverse the item once a vendor score change with no disparate-impact test is lined up to the same Fair Lending population. 2. Geographic application and origination heat map is closer to Temporary compensating control after a vendor score change with no disparate-impact test; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract. 3. Approve a documented exception is still live in geographic application and origination heat map for adverse-action notice operations lead in a credit union rolling out a special-purpose credit program. 4. Geographic application and origination heat map is missing the fact adverse-action notice operations lead needs after a vendor score change with no disparate-impact test; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 2. Match the adverse-action language to the facts in geographic application and origination heat map. 3. Check HMDA coding and underwriting policy against dealer overlays introduce prohibited. 4. For this Fair Lending Pricing and Credit Limits file, read geographic application and origination heat map against a vendor score change with no disparate-impact test 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 / Pricing and Credit Limits packet (geographic application and origination heat map after a vendor score change with no disparate-impact test). If geographic application and origination heat map cannot force a Fair Lending label under Pricing and Credit Limits, stop. If geographic application and origination heat map after a vendor score change with no disparate-impact test cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Pricing and Credit Limits close, adverse-action notice operations lead must do not infer a control or scheme beyond the transaction and entitlement evidence.