Assess whether dealer overlays introduce prohibited steering (cb7c93)

Situation

After a DOJ or CFPB monitor request for pricing files, model-reason-code mapping that does not match notices is what adverse-action notice operations lead can touch in a lender expanding into majority-minority census tracts. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Redlining and HMDA Data file.

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 model-reason-code mapping that does not match notices after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• Model-reason-code mapping that does not match notices reads as Remove access or reverse the item once a DOJ or CFPB monitor request for pricing files is lined up to the same Fair Lending population.
• Model-reason-code mapping that does not match notices is closer to Temporary compensating control after a DOJ or CFPB monitor request for pricing files; Remove access or reverse the item would over-claim this Redlining and HMDA Data extract.
• Approve a documented exception is still live in model-reason-code mapping that does not match notices for adverse-action notice operations lead in a lender expanding into majority-minority census tracts.
• Model-reason-code mapping that does not match notices is missing the fact adverse-action notice operations lead needs after a DOJ or CFPB monitor request for pricing files; stop this Fair Lending close.

Analysis required

• Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files.
• Flag any disparate-impact table adverse-action notice operations lead cannot explain from model-reason-code mapping that does not match notices.
• 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 model-reason-code mapping that does not match notices against a DOJ or CFPB monitor request for pricing files and write the one fact that would move dealer overlays introduce prohibited for adverse-action notice operations lead.