Assess whether dealer overlays introduce prohibited steering (2a8c0a)

Situation

The desk packet is manufactured-housing dealer overlay notes after a community complaint about appraisal gaps. 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 manufactured-housing dealer overlay notes after a community complaint about appraisal gaps.

Hypotheses to test

• The population in manufactured-housing dealer overlay notes is the one a community complaint about appraisal gaps named, so Remove access or reverse the item follows for this Examination and Notices file.
• The population in manufactured-housing dealer overlay notes is adjacent only to a community complaint about appraisal gaps; Temporary compensating control is the honest Fair Lending call.
• A small-business desk using a new vendor score already contained a community complaint about appraisal gaps before manufactured-housing dealer overlay notes arrived; no new Examination and Notices path.
• Provenance on manufactured-housing dealer overlay notes after a community complaint about appraisal gaps is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Compare manufactured-housing dealer overlay notes 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 manufactured-housing dealer overlay notes.
• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• For this Fair Lending Examination and Notices file, read manufactured-housing dealer overlay notes 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 / Examination and Notices packet (manufactured-housing dealer overlay notes after a community complaint about appraisal gaps). The follow-on Examination and Notices action is what HMDA data-quality manager does next: implement the option, assign an owner, and log the missing fact.