Assess whether dealer overlays introduce prohibited steering (6a882a)

Situation

A credit union rolling out a special-purpose credit program cannot treat a notice that cites 'other' as the principal reason 40% of the time as color commentary on appraisal-gap outcomes in majority-minority tracts. Second-review underwriter must close dealer overlays introduce prohibited from that extract under Fair Lending / Examination and Notices.

Decision

Second-review underwriter in a credit union rolling out a special-purpose credit program must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using appraisal-gap outcomes in majority-minority tracts after a notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• The population in appraisal-gap outcomes in majority-minority tracts is the one a notice that cites 'other' as the principal reason 40% of the time named, so Remove access or reverse the item follows for this Examination and Notices file.
• The population in appraisal-gap outcomes in majority-minority tracts is adjacent only to a notice that cites 'other' as the principal reason 40% of the time; Temporary compensating control is the honest Fair Lending call.
• A credit union rolling out a special-purpose credit program already contained a notice that cites 'other' as the principal reason 40% of the time before appraisal-gap outcomes in majority-minority tracts arrived; no new Examination and Notices path.
• Provenance on appraisal-gap outcomes in majority-minority tracts after a notice that cites 'other' as the principal reason 40% of the time is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Flag any disparate-impact table second-review underwriter cannot explain from appraisal-gap outcomes in majority-minority tracts.
• Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend.
• Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts.
• For this Fair Lending Examination and Notices file, read appraisal-gap outcomes in majority-minority tracts against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move dealer overlays introduce prohibited for second-review underwriter.