Assess whether dealer overlays introduce prohibited steering (d754ec)

Situation

A community complaint about appraisal gaps put credit-card limit assignment disparity table in front of exam-response coordinator in a manufactured-housing lender with dealer-originated files. This Fair Lending / CRA and Special-Purpose Programs close is dealer overlays introduce prohibited from credit-card limit assignment disparity table, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

Exam-response coordinator 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 credit-card limit assignment disparity table after a community complaint about appraisal gaps.

Hypotheses to test

• Credit-card limit assignment disparity table reads as Remove access or reverse the item once a community complaint about appraisal gaps is lined up to the same Fair Lending population.
• Credit-card limit assignment disparity table is closer to Temporary compensating control after a community complaint about appraisal gaps; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract.
• Approve a documented exception is still live in credit-card limit assignment disparity table for exam-response coordinator in a manufactured-housing lender with dealer-originated files.
• Credit-card limit assignment disparity table is missing the fact exam-response coordinator needs after a community complaint about appraisal gaps; stop this Fair Lending close.

Analysis required

• Flag any disparate-impact table exam-response coordinator cannot explain from credit-card limit assignment disparity table.
• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• Match the adverse-action language to the facts in credit-card limit assignment disparity table.
• For this Fair Lending CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table against a community complaint about appraisal gaps and write the one fact that would move dealer overlays introduce prohibited for exam-response coordinator.

Recommendation