Assess whether dealer overlays introduce prohibited steering (9d5bc5)

Situation

CRA strategist owns dealer overlays introduce prohibited inside a bank with thin HMDA LAR quality with credit-card limit assignment disparity table as the only packet. A HMDA resubmission that still fails quality edits is what changed the clock for this Fair Lending 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 credit-card limit assignment disparity table after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• Credit-card limit assignment disparity table reads as Remove access or reverse the item once a HMDA resubmission that still fails quality edits is lined up to the same Fair Lending population.
• Credit-card limit assignment disparity table is closer to Temporary compensating control after a HMDA resubmission that still fails quality edits; Remove access or reverse the item would over-claim this Examination and Notices extract.
• Approve a documented exception is still live in credit-card limit assignment disparity table for CRA strategist in a bank with thin HMDA LAR quality.
• Credit-card limit assignment disparity table is missing the fact CRA strategist needs after a HMDA resubmission that still fails quality edits; stop this Fair Lending close.

Analysis required

• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• Match the adverse-action language to the facts in credit-card limit assignment disparity table.
• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• For this Fair Lending Examination and Notices file, read credit-card limit assignment disparity table against a HMDA resubmission that still fails quality edits 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 (credit-card limit assignment disparity table after a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option credit-card limit assignment disparity table can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for CRA strategist in a bank with thin HMDA LAR quality.