Whether dealer overlays introduce prohibited steering from SPCP written plan

Situation

A HMDA resubmission that still fails quality edits put SPCP written plan versus actual originations in front of fair-lending officer in a manufactured-housing lender with dealer-originated files. This Fair Lending / Redlining and HMDA Data close is dealer overlays introduce prohibited from SPCP written plan versus actual originations, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

Fair-lending officer 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 SPCP written plan versus actual originations after a HMDA resubmission that still fails quality edits.

Hypotheses to test

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

Analysis required

• 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 SPCP written plan versus actual originations.
• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• For this Fair Lending Redlining and HMDA Data file, read SPCP written plan versus actual originations against a HMDA resubmission that still fails quality edits 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 / Redlining and HMDA Data packet (SPCP written plan versus actual originations after a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for fair-lending officer in a manufactured-housing lender with dealer-originated files.