Assess whether dealer overlays introduce prohibited steering (8c0367)

Situation

Fair-lending officer owns dealer overlays introduce prohibited inside a bank with thin HMDA LAR quality with geographic application and origination heat map as the only packet. An underwriter chat that used coded language is what changed the clock for this Fair Lending CRA and Special-Purpose Programs file.

Decision

Fair-lending officer 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 geographic application and origination heat map after an underwriter chat that used coded language.

Hypotheses to test

• Geographic application and origination heat map reads as Remove access or reverse the item once an underwriter chat that used coded language is lined up to the same Fair Lending population.
• Geographic application and origination heat map is closer to Temporary compensating control after an underwriter chat that used coded language; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract.
• Approve a documented exception is still live in geographic application and origination heat map for fair-lending officer in a bank with thin HMDA LAR quality.
• Geographic application and origination heat map is missing the fact fair-lending officer needs after an underwriter chat that used coded language; stop this Fair Lending close.

Analysis required

• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language.
• Flag any disparate-impact table fair-lending officer cannot explain from geographic application and origination heat map.
• For this Fair Lending CRA and Special-Purpose Programs file, read geographic application and origination heat map against an underwriter chat that used coded language and write the one fact that would move dealer overlays introduce prohibited for fair-lending officer.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (geographic application and origination heat map after an underwriter chat that used coded language). If geographic application and origination heat map cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If geographic application and origination heat map after an underwriter chat that used coded language cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, fair-lending officer must do not infer a control or scheme beyond the transaction and entitlement evidence.