Assess whether dealer overlays introduce prohibited steering (ce81f4)

Situation

A lender expanding into majority-minority census tracts cannot treat a HMDA resubmission that still fails quality edits as color commentary on underwriting exception log by branch. Adverse-action notice operations lead must close dealer overlays introduce prohibited from that extract under Fair Lending / Redlining and HMDA Data.

Decision

Adverse-action notice operations lead 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 underwriting exception log by branch after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• Underwriting exception log by branch reads as Remove access or reverse the item once a HMDA resubmission that still fails quality edits is lined up to the same Fair Lending population.
• Underwriting exception log by branch is closer to Temporary compensating control after a HMDA resubmission that still fails quality edits; 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 adverse-action notice operations lead in a lender expanding into majority-minority census tracts.
• Underwriting exception log by branch is missing the fact adverse-action notice operations lead needs after a HMDA resubmission that still fails quality edits; 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 HMDA resubmission that still fails quality edits.
• Flag any disparate-impact table adverse-action notice operations lead cannot explain from underwriting exception log by branch.
• Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend.
• For this Fair Lending Redlining and HMDA Data file, read underwriting exception log by branch against a HMDA resubmission that still fails quality edits 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 / Redlining and HMDA Data packet (underwriting exception log by branch after a HMDA resubmission that still fails quality edits). If underwriting exception log by branch cannot force a Fair Lending label under Redlining and HMDA Data, stop. If underwriting exception log by branch after a HMDA resubmission that still fails quality edits cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Redlining and HMDA Data close, adverse-action notice operations lead must do not infer a control or scheme beyond the transaction and entitlement evidence.