Assess whether dealer overlays introduce prohibited steering (0a78da)

Situation

After a community complaint about appraisal gaps, appraisal-gap outcomes in majority-minority tracts is what model-risk partner for credit scoring can touch in a credit-card issuer changing line-assignment logic. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this CRA and Special-Purpose Programs file.

Decision

Model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using appraisal-gap outcomes in majority-minority tracts after a community complaint about appraisal gaps.

Hypotheses to test

• Appraisal-gap outcomes in majority-minority tracts reads as Remove access or reverse the item once a community complaint about appraisal gaps is lined up to the same Fair Lending population.
• Appraisal-gap outcomes in majority-minority tracts is closer to Temporary compensating control after a community complaint about appraisal gaps; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract.
• Approve a documented exception is still live in appraisal-gap outcomes in majority-minority tracts for model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic.
• Appraisal-gap outcomes in majority-minority tracts is missing the fact model-risk partner for credit scoring needs after a community complaint about appraisal gaps; stop this Fair Lending close.

Analysis required

• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps.
• Flag any disparate-impact table model-risk partner for credit scoring cannot explain from appraisal-gap outcomes in majority-minority tracts.
• For this Fair Lending CRA and Special-Purpose Programs file, read appraisal-gap outcomes in majority-minority tracts against a community complaint about appraisal gaps and write the one fact that would move dealer overlays introduce prohibited for model-risk partner for credit scoring.

Recommendation