Assess whether dealer overlays introduce prohibited steering (ee157b)

Situation

Community-development lender owns dealer overlays introduce prohibited inside a mortgage company after a pricing-regression spike with small-business decline comparative file set as the only packet. A DOJ or CFPB monitor request for pricing files is what changed the clock for this Fair Lending Redlining and HMDA Data file.

Decision

Community-development lender in a mortgage company after a pricing-regression spike must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using small-business decline comparative file set after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• Authorize Remove access or reverse the item now; small-business decline comparative file set already has the discriminator after a DOJ or CFPB monitor request for pricing files.
• Keep Temporary compensating control in force until small-business decline comparative file set is completed after a DOJ or CFPB monitor request for pricing files for community-development lender.
• Treat small-business decline comparative file set as Approve a documented exception because both readings appear after a DOJ or CFPB monitor request for pricing files.
• Refuse a Fair Lending close: community-development lender does not have the page dealer overlays introduce prohibited turns on in small-business decline comparative file set.

Analysis required

• Match the adverse-action language to the facts in small-business decline comparative file set.
• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files.
• For this Fair Lending Redlining and HMDA Data file, read small-business decline comparative file set against a DOJ or CFPB monitor request for pricing files and write the one fact that would move dealer overlays introduce prohibited for community-development lender.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (small-business decline comparative file set after a DOJ or CFPB monitor request for pricing files). The follow-on Redlining and HMDA Data action is what community-development lender does next: implement the option, assign an owner, and log the missing fact.