Assess whether dealer overlays introduce prohibited steering (d5a374)

Situation

A credit-card issuer changing line-assignment logic cannot treat a branch that stopped taking applications in one ZIP as color commentary on model-reason-code mapping that does not match notices. Adverse-action notice operations lead must close dealer overlays introduce prohibited from that extract under Fair Lending / Examination and Notices.

Decision

Adverse-action notice operations lead 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 model-reason-code mapping that does not match notices after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• A branch that stopped taking applications in one ZIP is noise around an already-controlled Examination and Notices process in a credit-card issuer changing line-assignment logic, given model-reason-code mapping that does not match notices.
• A branch that stopped taking applications in one ZIP is the event in model-reason-code mapping that does not match notices that forces Remove access or reverse the item for adverse-action notice operations lead under Fair Lending.
• Model-reason-code mapping that does not match notices shows a one-file miss after a branch that stopped taking applications in one ZIP, not a Examination and Notices program failure.
• Model-reason-code mapping that does not match notices cannot decide dealer overlays introduce prohibited yet after a branch that stopped taking applications in one ZIP; hold is the only Fair Lending close a credit-card issuer changing line-assignment logic can defend.

Analysis required

• Flag any disparate-impact table adverse-action notice operations lead cannot explain from model-reason-code mapping that does not match notices.
• Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend.
• Match the adverse-action language to the facts in model-reason-code mapping that does not match notices.
• For this Fair Lending Examination and Notices file, read model-reason-code mapping that does not match notices against a branch that stopped taking applications in one ZIP and write the one fact that would move dealer overlays introduce prohibited for adverse-action notice operations lead.