Assess whether dealer overlays introduce prohibited steering (96df3f)

Situation

The CRA and Special-Purpose Programs desk packet is appraisal-gap outcomes in majority-minority tracts after a board asking if the bank should settle a matched-pair study. Fair-lending officer in a bank with thin HMDA LAR quality must name Remove access or reverse the item or Temporary compensating control for this Fair Lending file. Fair-lending officer in a bank with thin HMDA LAR quality has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending 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 appraisal-gap outcomes in majority-minority tracts after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• The population in appraisal-gap outcomes in majority-minority tracts is the one a board asking if the bank should settle a matched-pair study named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file.
• The population in appraisal-gap outcomes in majority-minority tracts is adjacent only to a board asking if the bank should settle a matched-pair study; Temporary compensating control is the honest Fair Lending call.
• A bank with thin HMDA LAR quality already contained a board asking if the bank should settle a matched-pair study before appraisal-gap outcomes in majority-minority tracts arrived; no new CRA and Special-Purpose Programs path.
• Provenance on appraisal-gap outcomes in majority-minority tracts after a board asking if the bank should settle a matched-pair study is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

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 appraisal-gap outcomes in majority-minority tracts.
• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• For this Fair Lending CRA and Special-Purpose Programs file, read appraisal-gap outcomes in majority-minority tracts 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.