Assess whether dealer overlays introduce prohibited steering (6141bb)

Situation

Adverse-action notice operations lead owns dealer overlays introduce prohibited inside a lender expanding into majority-minority census tracts with CRA assessment-area versus lending footprint as the only packet. A SPCP that originated almost no loans to the intended class is what changed the clock for this Fair Lending 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 CRA assessment-area versus lending footprint after a SPCP that originated almost no loans to the intended class.

Hypotheses to test

• Adverse-action notice operations lead can defend Remove access or reverse the item from CRA assessment-area versus lending footprint after a SPCP that originated almost no loans to the intended class in a Fair Lending challenge.
• Adverse-action notice operations lead cannot defend Remove access or reverse the item from CRA assessment-area versus lending footprint; Temporary compensating control is what the extract actually supports after a SPCP that originated almost no loans to the intended class.
• A SPCP that originated almost no loans to the intended class never reached the population in CRA assessment-area versus lending footprint — reopen intake, do not close dealer overlays introduce prohibited.
• Two facts in CRA assessment-area versus lending footprint after a SPCP that originated almost no loans to the intended class conflict for adverse-action notice operations lead; hold this Redlining and HMDA Data file.

Analysis required

• Match the adverse-action language to the facts in CRA assessment-area versus lending footprint.
• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class.
• For this Fair Lending Redlining and HMDA Data file, read CRA assessment-area versus lending footprint against a SPCP that originated almost no loans to the intended class and write the one fact that would move dealer overlays introduce prohibited for adverse-action notice operations lead.