Assess whether dealer overlays introduce prohibited steering (df4813)

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 DOJ or CFPB monitor request for pricing files 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 DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• Credit-card limit assignment disparity table reads as Remove access or reverse the item once a DOJ or CFPB monitor request for pricing files is lined up to the same Fair Lending population.
• Credit-card limit assignment disparity table is closer to Temporary compensating control after a DOJ or CFPB monitor request for pricing files; 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 second-review underwriter in a lender expanding into majority-minority census tracts.
• Credit-card limit assignment disparity table is missing the fact second-review underwriter needs after a DOJ or CFPB monitor request for pricing files; stop this Fair Lending close.

Analysis required

• 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.
• Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files.
• For this Fair Lending CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table against a DOJ or CFPB monitor request for pricing files and write the one fact that would move dealer overlays introduce prohibited for second-review underwriter.

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 a DOJ or CFPB monitor request for pricing files). 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 a DOJ or CFPB monitor request for pricing files cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, second-review underwriter must do not infer a control or scheme beyond the transaction and entitlement evidence.