Assess whether dealer overlays introduce prohibited steering (bbf8f8)

Situation

A manufactured-housing lender with dealer-originated files cannot treat a marketing mailer that skipped majority-minority tracts as color commentary on underwriting exception log by branch. Fair-lending officer must close dealer overlays introduce prohibited from that extract under Fair Lending / Redlining and HMDA Data.

Decision

Fair-lending officer in a manufactured-housing lender with dealer-originated files must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using underwriting exception log by branch after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Underwriting exception log by branch reads as Remove access or reverse the item once a marketing mailer that skipped majority-minority tracts is lined up to the same Fair Lending population.
• Underwriting exception log by branch is closer to Temporary compensating control after a marketing mailer that skipped majority-minority tracts; Remove access or reverse the item would over-claim this Redlining and HMDA Data extract.
• Approve a documented exception is still live in underwriting exception log by branch for fair-lending officer in a manufactured-housing lender with dealer-originated files.
• Underwriting exception log by branch is missing the fact fair-lending officer needs after a marketing mailer that skipped majority-minority tracts; stop this Fair Lending close.

Analysis required

• Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts.
• Flag any disparate-impact table fair-lending officer cannot explain from underwriting exception log by branch.
• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• For this Fair Lending Redlining and HMDA Data file, read underwriting exception log by branch against a marketing mailer that skipped majority-minority tracts and write the one fact that would move dealer overlays introduce prohibited for fair-lending officer.

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 (underwriting exception log by branch after a marketing mailer that skipped majority-minority tracts). The follow-on Redlining and HMDA Data action is what fair-lending officer does next: implement the option, assign an owner, and log the missing fact.