Assess whether dealer overlays introduce prohibited steering (c7a01b)

Situation

A board asking if the bank should settle a matched-pair study put mortgage pricing residual by prohibited-basis group in front of CRA strategist in an institution preparing for a redlining exam. This Fair Lending / Redlining and HMDA Data close is dealer overlays introduce prohibited from mortgage pricing residual by prohibited-basis group, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

CRA strategist in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using mortgage pricing residual by prohibited-basis group after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• Authorize Remove access or reverse the item now; mortgage pricing residual by prohibited-basis group already has the discriminator after a board asking if the bank should settle a matched-pair study.
• Keep Temporary compensating control in force until mortgage pricing residual by prohibited-basis group is completed after a board asking if the bank should settle a matched-pair study for CRA strategist.
• Treat mortgage pricing residual by prohibited-basis group as Approve a documented exception because both readings appear after a board asking if the bank should settle a matched-pair study.
• Refuse a Fair Lending close: CRA strategist does not have the page dealer overlays introduce prohibited turns on in mortgage pricing residual by prohibited-basis group.

Analysis required

• Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group.
• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study.
• For this Fair Lending Redlining and HMDA Data file, read mortgage pricing residual by prohibited-basis group against a board asking if the bank should settle a matched-pair study and write the one fact that would move dealer overlays introduce prohibited for CRA strategist.

Recommendation