Assess whether dealer overlays introduce prohibited steering (1e7675)

Situation

In a mortgage company after a pricing-regression spike, CRA assessment-area versus lending footprint is the only Examination and Notices extract after a HMDA resubmission that still fails quality edits that exam-response coordinator can use for dealer overlays introduce prohibited. Exam-response coordinator has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices close using CRA assessment-area versus lending footprint.

Decision

Exam-response coordinator in a mortgage company after a pricing-regression spike must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using CRA assessment-area versus lending footprint after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• Authorize Remove access or reverse the item now; CRA assessment-area versus lending footprint already has the discriminator after a HMDA resubmission that still fails quality edits.
• Keep Temporary compensating control in force until CRA assessment-area versus lending footprint is completed after a HMDA resubmission that still fails quality edits for exam-response coordinator.
• Treat CRA assessment-area versus lending footprint as Approve a documented exception because both readings appear after a HMDA resubmission that still fails quality edits.
• Refuse a Fair Lending close: exam-response coordinator does not have the page dealer overlays introduce prohibited turns on in CRA assessment-area versus lending footprint.

Analysis required

• Match the adverse-action language to the facts in CRA assessment-area versus lending footprint.
• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits.
• For this Fair Lending Examination and Notices file, read CRA assessment-area versus lending footprint against a HMDA resubmission that still fails quality edits and write the one fact that would move dealer overlays introduce prohibited for exam-response coordinator.

Recommendation