Assess whether dealer overlays introduce prohibited steering (ee5ba4)

Situation

A small-business desk using a new vendor score cannot treat a branch that stopped taking applications in one ZIP as color commentary on manufactured-housing dealer overlay notes. Second-review underwriter must close dealer overlays introduce prohibited from that extract under Fair Lending / Redlining and HMDA Data.

Decision

Second-review underwriter 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 manufactured-housing dealer overlay notes after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• Second-review underwriter can defend Remove access or reverse the item from manufactured-housing dealer overlay notes after a branch that stopped taking applications in one ZIP in a Fair Lending challenge.
• Second-review underwriter cannot defend Remove access or reverse the item from manufactured-housing dealer overlay notes; Temporary compensating control is what the extract actually supports after a branch that stopped taking applications in one ZIP.
• A branch that stopped taking applications in one ZIP never reached the population in manufactured-housing dealer overlay notes — reopen intake, do not close dealer overlays introduce prohibited.
• Two facts in manufactured-housing dealer overlay notes after a branch that stopped taking applications in one ZIP conflict for second-review underwriter; hold this Redlining and HMDA Data file.

Analysis required

• Flag any disparate-impact table second-review underwriter cannot explain from manufactured-housing dealer overlay notes.
• 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 manufactured-housing dealer overlay notes.
• For this Fair Lending Redlining and HMDA Data file, read manufactured-housing dealer overlay notes against a branch that stopped taking applications in one ZIP and write the one fact that would move dealer overlays introduce prohibited for second-review underwriter.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (manufactured-housing dealer overlay notes after a branch that stopped taking applications in one ZIP). Lead with the Fair Lending option manufactured-housing dealer overlay notes can support after a branch that stopped taking applications in one ZIP, then the two facts that force it, then the Monday action for second-review underwriter in a small-business desk using a new vendor score.