Whether dealer overlays introduce prohibited steering from CRA

Situation

The desk packet is CRA assessment-area versus lending footprint after a DOJ or CFPB monitor request for pricing files. Second-review underwriter in a credit-card issuer changing line-assignment logic has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits file.

Decision

Second-review underwriter in a credit-card issuer changing line-assignment logic 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 DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• A DOJ or CFPB monitor request for pricing files is noise around an already-controlled Pricing and Credit Limits process in a credit-card issuer changing line-assignment logic, given CRA assessment-area versus lending footprint.
• A DOJ or CFPB monitor request for pricing files is the event in CRA assessment-area versus lending footprint that forces Remove access or reverse the item for second-review underwriter under Fair Lending.
• CRA assessment-area versus lending footprint shows a one-file miss after a DOJ or CFPB monitor request for pricing files, not a Pricing and Credit Limits program failure.
• CRA assessment-area versus lending footprint cannot decide dealer overlays introduce prohibited yet after a DOJ or CFPB monitor request for pricing files; hold is the only Fair Lending close a credit-card issuer changing line-assignment logic can defend.

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 DOJ or CFPB monitor request for pricing files.
• For this Fair Lending Pricing and Credit Limits file, read CRA assessment-area versus lending footprint against a DOJ or CFPB monitor request for pricing files and write the one fact that would move dealer overlays introduce prohibited for second-review underwriter.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (CRA assessment-area versus lending footprint after a DOJ or CFPB monitor request for pricing files). If CRA assessment-area versus lending footprint cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent pages a credit-card issuer changing line-assignment logic does not have.