Assess whether dealer overlays introduce prohibited steering (cd2481)

Situation

A marketing mailer that skipped majority-minority tracts put model-reason-code mapping that does not match notices in front of CRA strategist in a bank with thin HMDA LAR quality. This Fair Lending / Examination and Notices close is dealer overlays introduce prohibited from model-reason-code mapping that does not match notices, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

CRA strategist 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 model-reason-code mapping that does not match notices after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Authorize Remove access or reverse the item now; model-reason-code mapping that does not match notices already has the discriminator after a marketing mailer that skipped majority-minority tracts.
• Keep Temporary compensating control in force until model-reason-code mapping that does not match notices is completed after a marketing mailer that skipped majority-minority tracts for CRA strategist.
• Treat model-reason-code mapping that does not match notices as Approve a documented exception because both readings appear after a marketing mailer that skipped majority-minority tracts.
• Refuse a Fair Lending close: CRA strategist does not have the page dealer overlays introduce prohibited turns on in model-reason-code mapping that does not match notices.

Analysis required

• 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 model-reason-code mapping that does not match notices.
• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• For this Fair Lending Examination and Notices file, read model-reason-code mapping that does not match notices against a marketing mailer that skipped majority-minority tracts and write the one fact that would move dealer overlays introduce prohibited for CRA strategist.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (model-reason-code mapping that does not match notices after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option model-reason-code mapping that does not match notices can support after a marketing mailer that skipped majority-minority tracts, then the two facts that force it, then the Monday action for CRA strategist in a bank with thin HMDA LAR quality.