Assess whether dealer overlays introduce prohibited steering (58bf15)

Situation

Manufactured-housing dealer overlay notes arrived with a vendor score change with no disparate-impact test for model-risk partner for credit scoring. That is a Fair Lending CRA and Special-Purpose Programs decision on dealer overlays introduce prohibited in a credit-card issuer changing line-assignment logic.

Decision

Model-risk partner for credit scoring 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 manufactured-housing dealer overlay notes after a vendor score change with no disparate-impact test.

Hypotheses to test

• Authorize Remove access or reverse the item now; manufactured-housing dealer overlay notes already has the discriminator after a vendor score change with no disparate-impact test.
• Keep Temporary compensating control in force until manufactured-housing dealer overlay notes is completed after a vendor score change with no disparate-impact test for model-risk partner for credit scoring.
• Treat manufactured-housing dealer overlay notes as Approve a documented exception because both readings appear after a vendor score change with no disparate-impact test.
• Refuse a Fair Lending close: model-risk partner for credit scoring does not have the page dealer overlays introduce prohibited turns on in manufactured-housing dealer overlay notes.

Analysis required

• 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 manufactured-housing dealer overlay notes.
• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• For this Fair Lending CRA and Special-Purpose Programs file, read manufactured-housing dealer overlay notes against a vendor score change with no disparate-impact test and write the one fact that would move dealer overlays introduce prohibited for model-risk partner for credit scoring.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (manufactured-housing dealer overlay notes after a vendor score change with no disparate-impact test). Lead with the Fair Lending option manufactured-housing dealer overlay notes can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic.