Assess whether dealer overlays introduce prohibited steering (532409)

Situation

A marketing mailer that skipped majority-minority tracts put CRA assessment-area versus lending footprint in front of exam-response coordinator in a mortgage company after a pricing-regression spike. This Fair Lending / Examination and Notices close is dealer overlays introduce prohibited from CRA assessment-area versus lending footprint, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

Exam-response coordinator 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 CRA assessment-area versus lending footprint after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Authorize Remove access or reverse the item now; CRA assessment-area versus lending footprint already has the discriminator after a marketing mailer that skipped majority-minority tracts.
• Keep Temporary compensating control in force until CRA assessment-area versus lending footprint is completed after a marketing mailer that skipped majority-minority tracts for exam-response coordinator.
• Treat CRA assessment-area versus lending footprint as Approve a documented exception because both readings appear after a marketing mailer that skipped majority-minority tracts.
• Refuse a Fair Lending close: exam-response coordinator does not have the page dealer overlays introduce prohibited turns on in CRA assessment-area versus lending footprint.

Analysis required

• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• 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.
• For this Fair Lending Examination and Notices file, read CRA assessment-area versus lending footprint against a marketing mailer that skipped majority-minority tracts and write the one fact that would move dealer overlays introduce prohibited for exam-response coordinator.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (CRA assessment-area versus lending footprint after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after a marketing mailer that skipped majority-minority tracts, then the two facts that force it, then the Monday action for exam-response coordinator in a mortgage company after a pricing-regression spike.