Assess whether dealer overlays introduce prohibited steering (8c56c4)

Situation

Second-review underwriter owns dealer overlays introduce prohibited inside a lender expanding into majority-minority census tracts with credit-card limit assignment disparity table as the only packet. A SPCP that originated almost no loans to the intended class is what changed the clock for this Fair Lending CRA and Special-Purpose Programs file.

Decision

Second-review underwriter in a lender expanding into majority-minority census tracts 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 SPCP that originated almost no loans to the intended class.

Hypotheses to test

• Second-review underwriter can defend Remove access or reverse the item from credit-card limit assignment disparity table after a SPCP that originated almost no loans to the intended class in a Fair Lending challenge.
• Second-review underwriter cannot defend Remove access or reverse the item from credit-card limit assignment disparity table; Temporary compensating control is what the extract actually supports after a SPCP that originated almost no loans to the intended class.
• A SPCP that originated almost no loans to the intended class never reached the population in credit-card limit assignment disparity table — reopen intake, do not close dealer overlays introduce prohibited.
• Two facts in credit-card limit assignment disparity table after a SPCP that originated almost no loans to the intended class conflict for second-review underwriter; hold this CRA and Special-Purpose Programs file.

Analysis required

• Test a documented exception versus a pattern a lender expanding into majority-minority census tracts 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 CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table against a SPCP that originated almost no loans to the intended class and write the one fact that would move dealer overlays introduce prohibited for second-review underwriter.

Recommendation