Assess whether dealer overlays introduce prohibited steering (eed589)

Situation

After a HMDA resubmission that still fails quality edits, small-business decline comparative file set is what adverse-action notice operations lead can touch in a lender expanding into majority-minority census tracts. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Redlining and HMDA Data file.

Decision

Adverse-action notice operations lead 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 HMDA resubmission that still fails quality edits.

Hypotheses to test

• Authorize Remove access or reverse the item now; small-business decline comparative file set already has the discriminator after a HMDA resubmission that still fails quality edits.
• Keep Temporary compensating control in force until small-business decline comparative file set is completed after a HMDA resubmission that still fails quality edits for adverse-action notice operations lead.
• Treat small-business decline comparative file set as Approve a documented exception because both readings appear after a HMDA resubmission that still fails quality edits.
• Refuse a Fair Lending close: adverse-action notice operations lead does not have the page dealer overlays introduce prohibited turns on in small-business decline comparative file set.

Analysis required

• Match the adverse-action language to the facts in small-business decline comparative file set.
• 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 HMDA resubmission that still fails quality edits.
• For this Fair Lending Redlining and HMDA Data file, read small-business decline comparative file set against a HMDA resubmission that still fails quality edits and write the one fact that would move dealer overlays introduce prohibited for adverse-action notice operations lead.

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 HMDA resubmission that still fails quality edits). Lead with the Fair Lending option small-business decline comparative file set can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for adverse-action notice operations lead in a lender expanding into majority-minority census tracts.