Assess whether dealer overlays introduce prohibited steering (1a5260)

Situation

Exam-response coordinator in a manufactured-housing lender with dealer-originated files has one working extract — CRA assessment-area versus lending footprint — after a CRA PE that called the assessment area too narrow. If CRA assessment-area versus lending footprint cannot support dealer overlays introduce prohibited, the honest Fair Lending output is hold.

Decision

Exam-response coordinator in a manufactured-housing lender with dealer-originated files 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 CRA PE that called the assessment area too narrow.

Hypotheses to test

• The population in CRA assessment-area versus lending footprint is the one a CRA PE that called the assessment area too narrow 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 CRA PE that called the assessment area too narrow; Temporary compensating control is the honest Fair Lending call.
• A manufactured-housing lender with dealer-originated files already contained a CRA PE that called the assessment area too narrow 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 CRA PE that called the assessment area too narrow is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Flag any disparate-impact table exam-response coordinator cannot explain from CRA assessment-area versus lending footprint.
• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• Match the adverse-action language to the facts in CRA assessment-area versus lending footprint.
• For this Fair Lending CRA and Special-Purpose Programs file, read CRA assessment-area versus lending footprint against a CRA PE that called the assessment area too narrow and write the one fact that would move dealer overlays introduce prohibited for exam-response coordinator.

Recommendation