Assess whether dealer overlays introduce prohibited steering after a notice

SITUATION Adverse-action notice operations lead is responsible for dealer overlays introduce prohibited in a credit union rolling out a special-purpose credit program, using underwriting exception log by branch as the only working extract. A notice that cites 'other' as the principal reason 40% of the time is what reset the timeline for this Fair Lending Pricing and Credit Limits file.

DECISION Adverse-action notice operations lead in a credit union rolling out a special-purpose credit program must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using underwriting exception log by branch after a notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. Adverse-action notice operations lead can defend Remove access or reverse the item from underwriting exception log by branch after a notice that cites 'other' as the principal reason 40% of the time in a Fair Lending challenge. 2. Adverse-action notice operations lead cannot defend Remove access or reverse the item from underwriting exception log by branch; Temporary compensating control is what the extract actually supports after a notice that cites 'other' as the principal reason 40% of the time. 3. A notice that cites 'other' as the principal reason 40% of the time never reached the population in underwriting exception log by branch — reopen intake, do not close dealer overlays introduce prohibited. 4. Two facts in underwriting exception log by branch after a notice that cites 'other' as the principal reason 40% of the time conflict for adverse-action notice operations lead; hold this Pricing and Credit Limits file.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in underwriting exception log by branch. 2. Check HMDA coding and underwriting policy against dealer overlays introduce prohibited. 3. Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time. 4. For this Fair Lending Pricing and Credit Limits file, read underwriting exception log by branch against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move dealer overlays introduce prohibited for adverse-action notice operations lead.

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 (underwriting exception log by branch after a notice that cites 'other' as the principal reason 40% of the time). Lead with the Fair Lending option underwriting exception log by branch can support after a notice that cites 'other' as the principal reason 40% of the time, then the two facts that force it, then the Monday action for adverse-action notice operations lead in a credit union rolling out a special-purpose credit program.