Assess whether dealer overlays introduce prohibited steering (6f3ce0)

Situation

After a CRA PE that called the assessment area too narrow, adverse-action notice principal-reason sample is what CRA strategist can touch in a bank with thin HMDA LAR quality. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Examination and Notices file.

Decision

CRA strategist in a bank with thin HMDA LAR quality must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using adverse-action notice principal-reason sample after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• The population in adverse-action notice principal-reason sample is the one a CRA PE that called the assessment area too narrow named, so Remove access or reverse the item follows for this Examination and Notices file.
• The population in adverse-action notice principal-reason sample is adjacent only to a CRA PE that called the assessment area too narrow; Temporary compensating control is the honest Fair Lending call.
• A bank with thin HMDA LAR quality already contained a CRA PE that called the assessment area too narrow before adverse-action notice principal-reason sample arrived; no new Examination and Notices path.
• Provenance on adverse-action notice principal-reason sample 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

• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow.
• Flag any disparate-impact table CRA strategist cannot explain from adverse-action notice principal-reason sample.
• For this Fair Lending Examination and Notices file, read adverse-action notice principal-reason sample against a CRA PE that called the assessment area too narrow and write the one fact that would move dealer overlays introduce prohibited for CRA strategist.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (adverse-action notice principal-reason sample after a CRA PE that called the assessment area too narrow). If adverse-action notice principal-reason sample cannot force a Fair Lending label under Examination and Notices, stop. If adverse-action notice principal-reason sample after a CRA PE that called the assessment area too narrow cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Examination and Notices close, CRA strategist must do not infer a control or scheme beyond the transaction and entitlement evidence.