Assess whether dealer overlays introduce prohibited steering (76f567)

Situation

A mortgage company after a pricing-regression spike cannot treat a board asking if the bank should settle a matched-pair study as color commentary on manufactured-housing dealer overlay notes. Community-development lender must close dealer overlays introduce prohibited from that extract under Fair Lending / Redlining and HMDA Data.

Decision

Community-development lender in a mortgage company after a pricing-regression spike must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using manufactured-housing dealer overlay notes after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• Community-development lender can defend Remove access or reverse the item from manufactured-housing dealer overlay notes after a board asking if the bank should settle a matched-pair study in a Fair Lending challenge.
• Community-development lender 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 board asking if the bank should settle a matched-pair study.
• A board asking if the bank should settle a matched-pair study 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 board asking if the bank should settle a matched-pair study conflict for community-development lender; hold this Redlining and HMDA Data file.

Analysis required

• Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study.
• Flag any disparate-impact table community-development lender cannot explain from manufactured-housing dealer overlay notes.
• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• For this Fair Lending Redlining and HMDA Data file, read manufactured-housing dealer overlay notes against a board asking if the bank should settle a matched-pair study and write the one fact that would move dealer overlays introduce prohibited for community-development lender.

Recommendation