Assess whether dealer overlays introduce prohibited steering (9bdf85)

Situation

After a board asking if the bank should settle a matched-pair study, adverse-action notice principal-reason sample is what fair-lending officer can touch in a bank with thin HMDA LAR quality. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this CRA and Special-Purpose Programs file.

Decision

Fair-lending officer 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 adverse-action notice principal-reason sample after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• Authorize Remove access or reverse the item now; adverse-action notice principal-reason sample already has the discriminator after a board asking if the bank should settle a matched-pair study.
• Keep Temporary compensating control in force until adverse-action notice principal-reason sample is completed after a board asking if the bank should settle a matched-pair study for fair-lending officer.
• Treat adverse-action notice principal-reason sample as Approve a documented exception because both readings appear after a board asking if the bank should settle a matched-pair study.
• Refuse a Fair Lending close: fair-lending officer does not have the page dealer overlays introduce prohibited turns on in adverse-action notice principal-reason sample.

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 adverse-action notice principal-reason sample.
• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• For this Fair Lending CRA and Special-Purpose Programs file, read adverse-action notice principal-reason sample against a board asking if the bank should settle a matched-pair study and write the one fact that would move dealer overlays introduce prohibited for fair-lending officer.

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 (adverse-action notice principal-reason sample after a board asking if the bank should settle a matched-pair study). Lead with the Fair Lending option adverse-action notice principal-reason sample can support after a board asking if the bank should settle a matched-pair study, then the two facts that force it, then the Monday action for fair-lending officer in a bank with thin HMDA LAR quality.