Assess whether dealer overlays introduce prohibited steering (f3fd91)

Situation

In a lender expanding into majority-minority census tracts, credit-card limit assignment disparity table is the evidence after an exception rate twice as high for one group after credit controls. Second-review underwriter has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs close using credit-card limit assignment disparity table.

Decision

Second-review underwriter 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 credit-card limit assignment disparity table after an exception rate twice as high for one group after credit controls.

Hypotheses to test

• The population in credit-card limit assignment disparity table is the one an exception rate twice as high for one group after credit controls named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file.
• The population in credit-card limit assignment disparity table is adjacent only to an exception rate twice as high for one group after credit controls; Temporary compensating control is the honest Fair Lending call.
• A lender expanding into majority-minority census tracts already contained an exception rate twice as high for one group after credit controls before credit-card limit assignment disparity table arrived; no new CRA and Special-Purpose Programs path.
• Provenance on credit-card limit assignment disparity table after an exception rate twice as high for one group after credit controls is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• Compare credit-card limit assignment disparity table 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 second-review underwriter cannot explain from credit-card limit assignment disparity table.
• For this Fair Lending CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table 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 second-review underwriter.