Assess whether dealer overlays introduce prohibited steering (20b94b)

Situation

In a small-business desk using a new vendor score, HMDA LAR validity and quality edits is the evidence after a vendor score change with no disparate-impact test. Adverse-action notice operations lead has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs close using HMDA LAR validity and quality edits.

Decision

Adverse-action notice operations lead 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 HMDA LAR validity and quality edits after a vendor score change with no disparate-impact test.

Hypotheses to test

• A vendor score change with no disparate-impact test is noise around an already-controlled CRA and Special-Purpose Programs process in a small-business desk using a new vendor score, given HMDA LAR validity and quality edits.
• A vendor score change with no disparate-impact test is the event in HMDA LAR validity and quality edits that forces Remove access or reverse the item for adverse-action notice operations lead under Fair Lending.
• HMDA LAR validity and quality edits shows a one-file miss after a vendor score change with no disparate-impact test, not a CRA and Special-Purpose Programs program failure.
• HMDA LAR validity and quality edits cannot decide dealer overlays introduce prohibited yet after a vendor score change with no disparate-impact test; hold is the only Fair Lending close a small-business desk using a new vendor score can defend.

Analysis required

• Flag any disparate-impact table adverse-action notice operations lead cannot explain from HMDA LAR validity and quality edits.
• 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 HMDA LAR validity and quality edits.
• For this Fair Lending CRA and Special-Purpose Programs file, read HMDA LAR validity and quality edits 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 / CRA and Special-Purpose Programs packet (HMDA LAR validity and quality edits after a vendor score change with no disparate-impact test). Lead with the Fair Lending option HMDA LAR validity and quality edits can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for adverse-action notice operations lead in a small-business desk using a new vendor score.