Assess whether dealer overlays introduce prohibited steering (64dd37)

Situation

The desk packet is model-reason-code mapping that does not match notices after a HMDA resubmission that still fails quality edits. HMDA data-quality manager in a small-business desk using a new vendor score has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices file.

Decision

HMDA data-quality manager in a small-business desk using a new vendor score 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 HMDA resubmission that still fails quality edits.

Hypotheses to test

• The population in model-reason-code mapping that does not match notices is the one a HMDA resubmission that still fails quality edits named, so Remove access or reverse the item follows for this Examination and Notices file.
• The population in model-reason-code mapping that does not match notices is adjacent only to a HMDA resubmission that still fails quality edits; Temporary compensating control is the honest Fair Lending call.
• A small-business desk using a new vendor score already contained a HMDA resubmission that still fails quality edits before model-reason-code mapping that does not match notices arrived; no new Examination and Notices path.
• Provenance on model-reason-code mapping that does not match notices after a HMDA resubmission that still fails quality edits is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• Match the adverse-action language to the facts in model-reason-code mapping that does not match notices.
• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• For this Fair Lending Examination and Notices file, read model-reason-code mapping that does not match notices against a HMDA resubmission that still fails quality edits 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 / Examination and Notices packet (model-reason-code mapping that does not match notices after a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option model-reason-code mapping that does not match notices can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for HMDA data-quality manager in a small-business desk using a new vendor score.