Assess whether dealer overlays introduce prohibited steering from CRA

SITUATION CRA assessment-area versus lending footprint arrived with a board asking if the bank should settle a matched-pair study for HMDA data-quality manager. That is a Fair Lending Pricing and Credit Limits decision on dealer overlays introduce prohibited in a lender expanding into majority-minority census tracts.

DECISION HMDA data-quality manager in a lender expanding into majority-minority census tracts 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 board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; CRA assessment-area versus lending footprint already has the discriminator after a board asking if the bank should settle a matched-pair study. 2. Keep Temporary compensating control in force until CRA assessment-area versus lending footprint is completed after a board asking if the bank should settle a matched-pair study for HMDA data-quality manager. 3. Treat CRA assessment-area versus lending footprint as Approve a documented exception because both readings appear after a board asking if the bank should settle a matched-pair study. 4. Refuse a Fair Lending close: HMDA data-quality manager does not have the decision dealer overlays introduce prohibited turns on in CRA assessment-area versus lending footprint.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 2. Match the adverse-action language to the facts in CRA assessment-area versus lending footprint. 3. Check HMDA coding and underwriting policy against dealer overlays introduce prohibited. 4. For this Fair Lending Pricing and Credit Limits file, read CRA assessment-area versus lending footprint 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 HMDA data-quality manager.

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 board asking if the bank should settle a matched-pair study). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after a board asking if the bank should settle a matched-pair study, then the two facts that force it, then the Monday action for HMDA data-quality manager in a lender expanding into majority-minority census tracts.

COMMAND RETURNS - Bottom-line Fair Lending option on dealer overlays introduce prohibited, then the evidence in CRA assessment-area versus lending footprint, then the action for HMDA data-quality manager - Hypothesis scorecard against CRA assessment-area versus lending footprint: supported / rejected / untestable - Missing page in CRA assessment-area versus lending footprint after a board asking if the bank should settle a matched-pair study, if any - Regulatory or exam hook Pricing and Credit Limits would cite