Assess whether dealer overlays introduce prohibited steering (a652a1)

Situation

The Examination and Notices desk packet is appraisal-gap outcomes in majority-minority tracts after a SPCP that originated almost no loans to the intended class. Exam-response coordinator in a mortgage company after a pricing-regression spike must name Remove access or reverse the item or Temporary compensating control for this Fair Lending file. Exam-response coordinator in a mortgage company after a pricing-regression spike has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices file.

Decision

Exam-response coordinator in a mortgage company after a pricing-regression spike must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using appraisal-gap outcomes in majority-minority tracts after a SPCP that originated almost no loans to the intended class.

Hypotheses to test

• Exam-response coordinator can defend Remove access or reverse the item from appraisal-gap outcomes in majority-minority tracts after a SPCP that originated almost no loans to the intended class in a Fair Lending challenge.
• Exam-response coordinator cannot defend Remove access or reverse the item from appraisal-gap outcomes in majority-minority tracts; Temporary compensating control is what the extract actually supports after a SPCP that originated almost no loans to the intended class.
• A SPCP that originated almost no loans to the intended class never reached the population in appraisal-gap outcomes in majority-minority tracts — reopen intake, do not close dealer overlays introduce prohibited.
• Two facts in appraisal-gap outcomes in majority-minority tracts after a SPCP that originated almost no loans to the intended class conflict for exam-response coordinator; hold this Examination and Notices file.

Analysis required

• Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts.
• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class.
• For this Fair Lending Examination and Notices file, read appraisal-gap outcomes in majority-minority tracts against a SPCP that originated almost no loans to the intended class and write the one fact that would move dealer overlays introduce prohibited for exam-response coordinator.