Assess whether dealer overlays introduce prohibited steering (dddcb8)

Situation

CRA strategist owns dealer overlays introduce prohibited inside an institution preparing for a redlining exam with small-business decline comparative file set as the only packet. An exception rate twice as high for one group after credit controls is what changed the clock for this Fair Lending Redlining and HMDA Data file.

Decision

CRA strategist in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using small-business decline comparative file set after an exception rate twice as high for one group after credit controls.

Hypotheses to test

• CRA strategist can defend Remove access or reverse the item from small-business decline comparative file set after an exception rate twice as high for one group after credit controls in a Fair Lending challenge.
• CRA strategist cannot defend Remove access or reverse the item from small-business decline comparative file set; Temporary compensating control is what the extract actually supports after an exception rate twice as high for one group after credit controls.
• An exception rate twice as high for one group after credit controls never reached the population in small-business decline comparative file set — reopen intake, do not close dealer overlays introduce prohibited.
• Two facts in small-business decline comparative file set after an exception rate twice as high for one group after credit controls conflict for CRA strategist; hold this Redlining and HMDA Data file.

Analysis required

• Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls.
• Flag any disparate-impact table CRA strategist cannot explain from small-business decline comparative file set.
• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• For this Fair Lending Redlining and HMDA Data file, read small-business decline comparative file set against an exception rate twice as high for one group after credit controls and write the one fact that would move dealer overlays introduce prohibited for CRA strategist.

Recommendation