Assess whether dealer overlays introduce prohibited steering (f76369)

Situation

HMDA data-quality manager in a credit union rolling out a special-purpose credit program has one working extract — appraisal-gap outcomes in majority-minority tracts — after an underwriter chat that used coded language. HMDA data-quality manager in a credit union rolling out a special-purpose credit program has appraisal-gap outcomes in majority-minority tracts after an underwriter chat that used coded language. If that extract cannot support dealer overlays introduce prohibited, the honest Fair Lending CRA and Special-Purpose Programs output is hold.

Decision

HMDA data-quality manager in a credit union rolling out a special-purpose credit program 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 an underwriter chat that used coded language.

Hypotheses to test

• An underwriter chat that used coded language is noise around an already-controlled CRA and Special-Purpose Programs process in a credit union rolling out a special-purpose credit program, given appraisal-gap outcomes in majority-minority tracts.
• An underwriter chat that used coded language is the event in appraisal-gap outcomes in majority-minority tracts that forces Remove access or reverse the item for HMDA data-quality manager under Fair Lending.
• Appraisal-gap outcomes in majority-minority tracts shows a one-file miss after an underwriter chat that used coded language, not a CRA and Special-Purpose Programs program failure.
• Appraisal-gap outcomes in majority-minority tracts cannot decide dealer overlays introduce prohibited yet after an underwriter chat that used coded language; hold is the only Fair Lending close a credit union rolling out a special-purpose credit program can defend.

Analysis required

• 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.
• Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language.
• For this Fair Lending CRA and Special-Purpose Programs file, read appraisal-gap outcomes in majority-minority tracts against an underwriter chat that used coded language and write the one fact that would move dealer overlays introduce prohibited for HMDA data-quality manager.