Assess whether dealer overlays introduce prohibited steering (303a49)

Situation

Fair-lending officer in an institution preparing for a redlining exam has one working extract — SPCP written plan versus actual originations — after a CRA PE that called the assessment area too narrow. If SPCP written plan versus actual originations cannot support dealer overlays introduce prohibited, the honest Fair Lending output is hold.

Decision

Fair-lending officer in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using SPCP written plan versus actual originations after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• Authorize Remove access or reverse the item now; SPCP written plan versus actual originations already has the discriminator after a CRA PE that called the assessment area too narrow.
• Keep Temporary compensating control in force until SPCP written plan versus actual originations is completed after a CRA PE that called the assessment area too narrow for fair-lending officer.
• Treat SPCP written plan versus actual originations as Approve a documented exception because both readings appear after a CRA PE that called the assessment area too narrow.
• Refuse a Fair Lending close: fair-lending officer does not have the page dealer overlays introduce prohibited turns on in SPCP written plan versus actual originations.

Analysis required

• Match the adverse-action language to the facts in SPCP written plan versus actual originations.
• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow.
• For this Fair Lending Examination and Notices file, read SPCP written plan versus actual originations against a CRA PE that called the assessment area too narrow 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 / Examination and Notices packet (SPCP written plan versus actual originations after a CRA PE that called the assessment area too narrow). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a CRA PE that called the assessment area too narrow, then the two facts that force it, then the Monday action for fair-lending officer in an institution preparing for a redlining exam.