Whether dealer overlays introduce prohibited steering

Situation

Dealer overlays introduce prohibited sits with HMDA data-quality manager because an exception rate twice as high for one group after credit controls hit a lender expanding into majority-minority census tracts. Evidence is manufactured-housing dealer overlay notes; write the Fair Lending Pricing and Credit Limits option that extract can carry.

Decision

HMDA data-quality manager in a lender expanding into majority-minority census tracts must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using manufactured-housing dealer overlay notes after an exception rate twice as high for one group after credit controls.

Hypotheses to test

• The population in manufactured-housing dealer overlay notes is the one an exception rate twice as high for one group after credit controls named, so Remove access or reverse the item follows for this Pricing and Credit Limits file.
• The population in manufactured-housing dealer overlay notes is adjacent only to an exception rate twice as high for one group after credit controls; Temporary compensating control is the honest Fair Lending call.
• A lender expanding into majority-minority census tracts already contained an exception rate twice as high for one group after credit controls before manufactured-housing dealer overlay notes arrived; no new Pricing and Credit Limits path.
• Provenance on manufactured-housing dealer overlay notes after an exception rate twice as high for one group after credit controls is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Flag any disparate-impact table HMDA data-quality manager cannot explain from manufactured-housing dealer overlay notes.
• Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend.
• Match the adverse-action language to the facts in manufactured-housing dealer overlay notes.
• For this Fair Lending Pricing and Credit Limits file, read manufactured-housing dealer overlay notes against an exception rate twice as high for one group after credit controls and write the one fact that would move dealer overlays introduce prohibited for HMDA data-quality manager.

Recommendation