Assess whether dealer overlays introduce prohibited steering (29947c)

Situation

Second-review underwriter owns dealer overlays introduce prohibited inside a small-business desk using a new vendor score with credit-card limit assignment disparity table as the only packet. A CRA PE that called the assessment area too narrow is what changed the clock for this Fair Lending Redlining and HMDA Data file.

Decision

Second-review underwriter in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using credit-card limit assignment disparity table after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• Second-review underwriter can defend Remove access or reverse the item from credit-card limit assignment disparity table after a CRA PE that called the assessment area too narrow in a Fair Lending challenge.
• Second-review underwriter cannot defend Remove access or reverse the item from credit-card limit assignment disparity table; Temporary compensating control is what the extract actually supports after a CRA PE that called the assessment area too narrow.
• A CRA PE that called the assessment area too narrow never reached the population in credit-card limit assignment disparity table — reopen intake, do not close dealer overlays introduce prohibited.
• Two facts in credit-card limit assignment disparity table after a CRA PE that called the assessment area too narrow conflict for second-review underwriter; hold this Redlining and HMDA Data file.

Analysis required

• Match the adverse-action language to the facts in credit-card limit assignment disparity table.
• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow.
• For this Fair Lending Redlining and HMDA Data file, read credit-card limit assignment disparity table against a CRA PE that called the assessment area too narrow 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 / Redlining and HMDA Data packet (credit-card limit assignment disparity table after a CRA PE that called the assessment area too narrow). Lead with the Fair Lending option credit-card limit assignment disparity table can support after a CRA PE that called the assessment area too narrow, then the two facts that force it, then the Monday action for second-review underwriter in a small-business desk using a new vendor score.