Assess whether dealer overlays introduce prohibited steering (41ad96)

Situation

Credit-card limit assignment disparity table arrived with an underwriter chat that used coded language for exam-response coordinator. That is a Fair Lending CRA and Special-Purpose Programs decision on dealer overlays introduce prohibited in a manufactured-housing lender with dealer-originated files.

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 credit-card limit assignment disparity table after an underwriter chat that used coded language.

Hypotheses to test

• Credit-card limit assignment disparity table reads as Remove access or reverse the item once an underwriter chat that used coded language is lined up to the same Fair Lending population.
• Credit-card limit assignment disparity table is closer to Temporary compensating control after an underwriter chat that used coded language; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract.
• Approve a documented exception is still live in credit-card limit assignment disparity table for exam-response coordinator in a manufactured-housing lender with dealer-originated files.
• Credit-card limit assignment disparity table is missing the fact exam-response coordinator needs after an underwriter chat that used coded language; stop this Fair Lending close.

Analysis required

• Flag any disparate-impact table exam-response coordinator cannot explain from credit-card limit assignment disparity table.
• 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 credit-card limit assignment disparity table.
• For this Fair Lending CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table against an underwriter chat that used coded language 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 / CRA and Special-Purpose Programs packet (credit-card limit assignment disparity table after an underwriter chat that used coded language). If credit-card limit assignment disparity table cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If credit-card limit assignment disparity table after an underwriter chat that used coded language cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, exam-response coordinator must do not infer a control or scheme beyond the transaction and entitlement evidence.