Assess whether dealer overlays introduce prohibited steering (947a3c)

Situation

Model-reason-code mapping that does not match notices arrived with an exception rate twice as high for one group after credit controls for CRA strategist. That is a Fair Lending CRA and Special-Purpose Programs decision on dealer overlays introduce prohibited in a mortgage company after a pricing-regression spike.

Decision

CRA strategist 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 model-reason-code mapping that does not match notices after an exception rate twice as high for one group after credit controls.

Hypotheses to test

• Authorize Remove access or reverse the item now; model-reason-code mapping that does not match notices already has the discriminator after an exception rate twice as high for one group after credit controls.
• Keep Temporary compensating control in force until model-reason-code mapping that does not match notices is completed after an exception rate twice as high for one group after credit controls for CRA strategist.
• Treat model-reason-code mapping that does not match notices as Approve a documented exception because both readings appear after an exception rate twice as high for one group after credit controls.
• Refuse a Fair Lending close: CRA strategist does not have the page dealer overlays introduce prohibited turns on in model-reason-code mapping that does not match notices.

Analysis required

• Match the adverse-action language to the facts in model-reason-code mapping that does not match notices.
• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• Compare model-reason-code mapping that does not match notices 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 CRA and Special-Purpose Programs file, read model-reason-code mapping that does not match notices 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 CRA strategist.

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 (model-reason-code mapping that does not match notices after an exception rate twice as high for one group after credit controls). If model-reason-code mapping that does not match notices cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If model-reason-code mapping that does not match notices after an exception rate twice as high for one group after credit controls cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, CRA strategist must do not infer a control or scheme beyond the transaction and entitlement evidence.