Assess whether dealer overlays introduce prohibited steering (c23680)

Situation

Adverse-action notice operations lead owns dealer overlays introduce prohibited inside a credit-card issuer changing line-assignment logic with appraisal-gap outcomes in majority-minority tracts as the only packet. A branch that stopped taking applications in one ZIP is what changed the clock for this Fair Lending Examination and Notices file.

Decision

Adverse-action notice operations lead 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 branch that stopped taking applications in one ZIP.

Hypotheses to test

• Appraisal-gap outcomes in majority-minority tracts reads as Remove access or reverse the item once a branch that stopped taking applications in one ZIP is lined up to the same Fair Lending population.
• Appraisal-gap outcomes in majority-minority tracts is closer to Temporary compensating control after a branch that stopped taking applications in one ZIP; Remove access or reverse the item would over-claim this Examination and Notices extract.
• Approve a documented exception is still live in appraisal-gap outcomes in majority-minority tracts for adverse-action notice operations lead in a credit-card issuer changing line-assignment logic.
• Appraisal-gap outcomes in majority-minority tracts is missing the fact adverse-action notice operations lead needs after a branch that stopped taking applications in one ZIP; stop this Fair Lending close.

Analysis required

• Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP.
• Flag any disparate-impact table adverse-action notice operations lead cannot explain from appraisal-gap outcomes in majority-minority tracts.
• Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend.
• For this Fair Lending Examination and Notices file, read appraisal-gap outcomes in majority-minority tracts against a branch that stopped taking applications in one ZIP and write the one fact that would move dealer overlays introduce prohibited for adverse-action notice operations lead.

Recommendation