Assess whether dealer overlays introduce prohibited steering (1c739e)

Situation

Geographic application and origination heat map arrived with a CRA PE that called the assessment area too narrow for community-development lender. That is a Fair Lending Examination and Notices decision on dealer overlays introduce prohibited in a manufactured-housing lender with dealer-originated files.

Decision

Community-development lender 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 geographic application and origination heat map after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• Community-development lender can defend Remove access or reverse the item from geographic application and origination heat map after a CRA PE that called the assessment area too narrow in a Fair Lending challenge.
• Community-development lender cannot defend Remove access or reverse the item from geographic application and origination heat map; Temporary compensating control is what the extract actually supports after a CRA PE that called the assessment area too narrow.
• A CRA PE that called the assessment area too narrow never reached the population in geographic application and origination heat map — reopen intake, do not close dealer overlays introduce prohibited.
• Two facts in geographic application and origination heat map after a CRA PE that called the assessment area too narrow conflict for community-development lender; hold this Examination and Notices file.

Analysis required

• Match the adverse-action language to the facts in geographic application and origination heat map.
• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow.
• For this Fair Lending Examination and Notices file, read geographic application and origination heat map against a CRA PE that called the assessment area too narrow and write the one fact that would move dealer overlays introduce prohibited for community-development lender.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (geographic application and origination heat map after a CRA PE that called the assessment area too narrow). If geographic application and origination heat map cannot force a Fair Lending label under Examination and Notices, stop. Do not invent pages a manufactured-housing lender with dealer-originated files does not have.