Assess whether dealer overlays introduce prohibited steering (98db3d)

Situation

After an underwriter chat that used coded language, underwriting exception log by branch is what fair-lending officer can touch in a bank with thin HMDA LAR quality. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this CRA and Special-Purpose Programs file.

Decision

Fair-lending officer in a bank with thin HMDA LAR quality must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using underwriting exception log by branch after an underwriter chat that used coded language.

Hypotheses to test

• The population in underwriting exception log by branch is the one an underwriter chat that used coded language named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file.
• The population in underwriting exception log by branch is adjacent only to an underwriter chat that used coded language; Temporary compensating control is the honest Fair Lending call.
• A bank with thin HMDA LAR quality already contained an underwriter chat that used coded language before underwriting exception log by branch arrived; no new CRA and Special-Purpose Programs path.
• Provenance on underwriting exception log by branch after an underwriter chat that used coded language is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Flag any disparate-impact table fair-lending officer cannot explain from underwriting exception log by branch.
• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• Match the adverse-action language to the facts in underwriting exception log by branch.
• For this Fair Lending CRA and Special-Purpose Programs file, read underwriting exception log by branch against an underwriter chat that used coded language and write the one fact that would move dealer overlays introduce prohibited for fair-lending officer.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (underwriting exception log by branch after an underwriter chat that used coded language). If underwriting exception log by branch cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If underwriting exception log by branch after an underwriter chat that used coded language cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, fair-lending officer must do not infer a control or scheme beyond the transaction and entitlement evidence.