Assess whether dealer overlays introduce prohibited steering from SPCP

SITUATION CRA strategist received SPCP written plan versus actual originations after a board asking if the bank should settle a matched-pair study in a manufactured-housing lender with dealer-originated files. Remove access or reverse the item or Temporary compensating control must follow from that extract if the file can settle whether dealer overlays introduce prohibited steering.

DECISION CRA strategist 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 board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. The population in SPCP written plan versus actual originations is the one a board asking if the bank should settle a matched-pair study named, so Remove access or reverse the item follows for this Pricing and Credit Limits file. 2. The population in SPCP written plan versus actual originations is adjacent only to a board asking if the bank should settle a matched-pair study; Temporary compensating control is the honest Fair Lending call. 3. A manufactured-housing lender with dealer-originated files already contained a board asking if the bank should settle a matched-pair study before SPCP written plan versus actual originations arrived; no new Pricing and Credit Limits path. 4. Provenance on SPCP written plan versus actual originations after a board asking if the bank should settle a matched-pair study is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 2. Match the adverse-action language to the facts in SPCP written plan versus actual originations. 3. Check HMDA coding and underwriting policy against dealer overlays introduce prohibited. 4. For this Fair Lending Pricing and Credit Limits file, read SPCP written plan versus actual originations 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 CRA strategist.

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 (SPCP written plan versus actual originations after a board asking if the bank should settle a matched-pair study). Lead with the Fair Lending option SPCP written plan versus actual originations 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 CRA strategist in a manufactured-housing lender with dealer-originated files.