Assess whether dealer overlays introduce prohibited steering (5d754e)

Situation

Second-review underwriter owns dealer overlays introduce prohibited inside a credit union rolling out a special-purpose credit program with geographic application and origination heat map as the only packet. A marketing mailer that skipped majority-minority tracts is what changed the clock for this Fair Lending Examination and Notices file.

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 geographic application and origination heat map after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Second-review underwriter can defend Remove access or reverse the item from geographic application and origination heat map after a marketing mailer that skipped majority-minority tracts in a Fair Lending challenge.
• Second-review underwriter cannot defend Remove access or reverse the item from geographic application and origination heat map; Temporary compensating control is what the extract actually supports after a marketing mailer that skipped majority-minority tracts.
• A marketing mailer that skipped majority-minority tracts never reached the population in geographic application and origination heat map — reopen intake, do not close dealer overlays introduce prohibited.
• Two facts in geographic application and origination heat map after a marketing mailer that skipped majority-minority tracts conflict for second-review underwriter; hold this Examination and Notices file.

Analysis required

• 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.
• Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts.
• For this Fair Lending Examination and Notices file, read geographic application and origination heat map against a marketing mailer that skipped majority-minority tracts and write the one fact that would move dealer overlays introduce prohibited for second-review underwriter.

Recommendation