Assess whether dealer overlays introduce prohibited steering (30652b)

Situation

A community complaint about appraisal gaps put small-business decline comparative file set in front of HMDA data-quality manager in a credit-card issuer changing line-assignment logic. This Fair Lending / Redlining and HMDA Data close is dealer overlays introduce prohibited from small-business decline comparative file set, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

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 small-business decline comparative file set after a community complaint about appraisal gaps.

Hypotheses to test

• Authorize Remove access or reverse the item now; small-business decline comparative file set already has the discriminator after a community complaint about appraisal gaps.
• Keep Temporary compensating control in force until small-business decline comparative file set is completed after a community complaint about appraisal gaps for HMDA data-quality manager.
• Treat small-business decline comparative file set as Approve a documented exception because both readings appear after a community complaint about appraisal gaps.
• Refuse a Fair Lending close: HMDA data-quality manager does not have the page dealer overlays introduce prohibited turns on in small-business decline comparative file set.

Analysis required

• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps.
• Flag any disparate-impact table HMDA data-quality manager cannot explain from small-business decline comparative file set.
• For this Fair Lending Redlining and HMDA Data file, read small-business decline comparative file set against a community complaint about appraisal gaps 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 / Redlining and HMDA Data packet (small-business decline comparative file set after a community complaint about appraisal gaps). Lead with the Fair Lending option small-business decline comparative file set can support after a community complaint about appraisal gaps, then the two facts that force it, then the Monday action for HMDA data-quality manager in a credit-card issuer changing line-assignment logic.