Assess whether dealer overlays introduce prohibited steering (bbedb7)

Situation

Dealer overlays introduce prohibited sits with exam-response coordinator because an exception rate twice as high for one group after credit controls hit a mortgage company after a pricing-regression spike. Evidence is SPCP written plan versus actual originations; 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 SPCP written plan versus actual originations after an exception rate twice as high for one group after credit controls.

Hypotheses to test

• An exception rate twice as high for one group after credit controls is noise around an already-controlled Examination and Notices process in a mortgage company after a pricing-regression spike, given SPCP written plan versus actual originations.
• An exception rate twice as high for one group after credit controls is the event in SPCP written plan versus actual originations that forces Remove access or reverse the item for exam-response coordinator under Fair Lending.
• SPCP written plan versus actual originations shows a one-file miss after an exception rate twice as high for one group after credit controls, not a Examination and Notices program failure.
• SPCP written plan versus actual originations cannot decide dealer overlays introduce prohibited yet after an exception rate twice as high for one group after credit controls; hold is the only Fair Lending close a mortgage company after a pricing-regression spike can defend.

Analysis required

• Match the adverse-action language to the facts in SPCP written plan versus actual originations.
• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls.
• For this Fair Lending Examination and Notices file, read SPCP written plan versus actual originations against an exception rate twice as high for one group after credit controls and write the one fact that would move dealer overlays introduce prohibited for exam-response coordinator.