Assess whether dealer overlays introduce prohibited steering (0afd7c)

Situation

A small-business desk using a new vendor score cannot treat a community complaint about appraisal gaps as color commentary on CRA assessment-area versus lending footprint. Adverse-action notice operations lead must close dealer overlays introduce prohibited from that extract under Fair Lending / CRA and Special-Purpose Programs.

Decision

Adverse-action notice operations lead 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 CRA assessment-area versus lending footprint after a community complaint about appraisal gaps.

Hypotheses to test

• The population in CRA assessment-area versus lending footprint is the one a community complaint about appraisal gaps named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file.
• The population in CRA assessment-area versus lending footprint 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 CRA assessment-area versus lending footprint arrived; no new CRA and Special-Purpose Programs path.
• Provenance on CRA assessment-area versus lending footprint 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

• 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 community complaint about appraisal gaps.
• For this Fair Lending CRA and Special-Purpose Programs file, read CRA assessment-area versus lending footprint against a community complaint about appraisal gaps 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 / CRA and Special-Purpose Programs packet (CRA assessment-area versus lending footprint after a community complaint about appraisal gaps). The follow-on CRA and Special-Purpose Programs action is what adverse-action notice operations lead does next: implement the option, assign an owner, and log the missing fact.