Assess whether dealer overlays introduce prohibited steering (40b4cf)

Situation

The desk packet is mortgage pricing residual by prohibited-basis group after a notice that cites 'other' as the principal reason 40% of the time. HMDA data-quality manager in a credit-card issuer changing line-assignment logic has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data file.

Decision

HMDA data-quality manager 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 mortgage pricing residual by prohibited-basis group after a notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• The population in mortgage pricing residual by prohibited-basis group is the one a notice that cites 'other' as the principal reason 40% of the time named, so Remove access or reverse the item follows for this Redlining and HMDA Data file.
• The population in mortgage pricing residual by prohibited-basis group is adjacent only to a notice that cites 'other' as the principal reason 40% of the time; Temporary compensating control is the honest Fair Lending call.
• A credit-card issuer changing line-assignment logic already contained a notice that cites 'other' as the principal reason 40% of the time before mortgage pricing residual by prohibited-basis group arrived; no new Redlining and HMDA Data path.
• Provenance on mortgage pricing residual by prohibited-basis group after a notice that cites 'other' as the principal reason 40% of the time 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 mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time.
• Flag any disparate-impact table HMDA data-quality manager cannot explain from mortgage pricing residual by prohibited-basis group.
• For this Fair Lending Redlining and HMDA Data file, read mortgage pricing residual by prohibited-basis group against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move dealer overlays introduce prohibited for HMDA data-quality manager.