Assess whether dealer overlays introduce prohibited steering (b27051)

Situation

A small-business desk using a new vendor score cannot treat a DOJ or CFPB monitor request for pricing files as color commentary on manufactured-housing dealer overlay notes. HMDA data-quality manager must close dealer overlays introduce prohibited from that extract under Fair Lending / Examination and Notices.

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 DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• The population in manufactured-housing dealer overlay notes is the one a DOJ or CFPB monitor request for pricing files 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 DOJ or CFPB monitor request for pricing files; Temporary compensating control is the honest Fair Lending call.
• A small-business desk using a new vendor score already contained a DOJ or CFPB monitor request for pricing files before manufactured-housing dealer overlay notes arrived; no new Examination and Notices path.
• Provenance on manufactured-housing dealer overlay notes after a DOJ or CFPB monitor request for pricing files 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 DOJ or CFPB monitor request for pricing files.
• 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 DOJ or CFPB monitor request for pricing files 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 DOJ or CFPB monitor request for pricing files). If manufactured-housing dealer overlay notes cannot force a Fair Lending label under Examination and Notices, stop. If manufactured-housing dealer overlay notes after a DOJ or CFPB monitor request for pricing files cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Examination and Notices close, HMDA data-quality manager must do not infer a control or scheme beyond the transaction and entitlement evidence.