Assess whether dealer overlays introduce prohibited steering (10e592)

Situation

Dealer overlays introduce prohibited sits with exam-response coordinator because a branch that stopped taking applications in one ZIP hit a mortgage company after a pricing-regression spike. Evidence is CRA assessment-area versus lending footprint; write the Fair Lending Examination and Notices option that extract can carry.

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 CRA assessment-area versus lending footprint after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• CRA assessment-area versus lending footprint reads as Remove access or reverse the item once a branch that stopped taking applications in one ZIP is lined up to the same Fair Lending population.
• CRA assessment-area versus lending footprint is closer to Temporary compensating control after a branch that stopped taking applications in one ZIP; Remove access or reverse the item would over-claim this Examination and Notices extract.
• Approve a documented exception is still live in CRA assessment-area versus lending footprint for exam-response coordinator in a mortgage company after a pricing-regression spike.
• CRA assessment-area versus lending footprint is missing the fact exam-response coordinator needs after a branch that stopped taking applications in one ZIP; stop this Fair Lending close.

Analysis required

• Match the adverse-action language to the facts in CRA assessment-area versus lending footprint.
• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP.
• For this Fair Lending Examination and Notices file, read CRA assessment-area versus lending footprint against a branch that stopped taking applications in one ZIP and write the one fact that would move dealer overlays introduce prohibited for exam-response coordinator.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (CRA assessment-area versus lending footprint after a branch that stopped taking applications in one ZIP). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after a branch that stopped taking applications in one ZIP, then the two facts that force it, then the Monday action for exam-response coordinator in a mortgage company after a pricing-regression spike.