Assess whether dealer overlays introduce prohibited steering (cc0498)

SITUATION In a lender expanding into majority-minority census tracts, small-business decline comparative file set is the evidence after a marketing mailer that skipped majority-minority tracts. HMDA data-quality manager has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits close using small-business decline comparative file set.

DECISION HMDA data-quality manager 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 small-business decline comparative file set after a marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; small-business decline comparative file set already has the discriminator after a marketing mailer that skipped majority-minority tracts. 2. Keep Temporary compensating control in force until small-business decline comparative file set is completed after a marketing mailer that skipped majority-minority tracts for HMDA data-quality manager. 3. Treat small-business decline comparative file set as Approve a documented exception because both readings appear after a marketing mailer that skipped majority-minority tracts. 4. Refuse a Fair Lending close: HMDA data-quality manager does not have the decision dealer overlays introduce prohibited turns on in small-business decline comparative file set.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against dealer overlays introduce prohibited. 2. Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts. 3. Flag any disparate-impact table HMDA data-quality manager cannot explain from small-business decline comparative file set. 4. For this Fair Lending Pricing and Credit Limits file, read small-business decline comparative file set against a marketing mailer that skipped majority-minority tracts and write the one fact that would move dealer overlays introduce prohibited for HMDA data-quality manager.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (small-business decline comparative file set after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option small-business decline comparative file set can support after a marketing mailer that skipped majority-minority tracts, then the two facts that force it, then the Monday action for HMDA data-quality manager in a lender expanding into majority-minority census tracts.