Assess whether dealer overlays introduce prohibited steering (2379c1)

Situation

Exam-response coordinator in a manufactured-housing lender with dealer-originated files has one working extract — geographic application and origination heat map — after a board asking if the bank should settle a matched-pair study. If geographic application and origination heat map cannot support dealer overlays introduce prohibited, the honest Fair Lending output is hold.

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 geographic application and origination heat map after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• A board asking if the bank should settle a matched-pair study is noise around an already-controlled CRA and Special-Purpose Programs process in a manufactured-housing lender with dealer-originated files, given geographic application and origination heat map.
• A board asking if the bank should settle a matched-pair study is the event in geographic application and origination heat map that forces Remove access or reverse the item for exam-response coordinator under Fair Lending.
• Geographic application and origination heat map shows a one-file miss after a board asking if the bank should settle a matched-pair study, not a CRA and Special-Purpose Programs program failure.
• Geographic application and origination heat map cannot decide dealer overlays introduce prohibited yet after a board asking if the bank should settle a matched-pair study; hold is the only Fair Lending close a manufactured-housing lender with dealer-originated files can defend.

Analysis required

• 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 geographic application and origination heat map.
• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• For this Fair Lending CRA and Special-Purpose Programs file, read geographic application and origination heat map 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 exam-response coordinator.