Whether dealer overlays introduce prohibited steering from appraisal-gap

Situation

A manufactured-housing lender with dealer-originated files cannot treat an exception rate twice as high for one group after credit controls as color commentary on appraisal-gap outcomes in majority-minority tracts. CRA strategist must close dealer overlays introduce prohibited from that extract under Fair Lending / Pricing and Credit Limits.

Decision

CRA strategist 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 appraisal-gap outcomes in majority-minority tracts after an exception rate twice as high for one group after credit controls.

Hypotheses to test

• An exception rate twice as high for one group after credit controls is noise around an already-controlled Pricing and Credit Limits process in a manufactured-housing lender with dealer-originated files, given appraisal-gap outcomes in majority-minority tracts.
• An exception rate twice as high for one group after credit controls is the event in appraisal-gap outcomes in majority-minority tracts that forces Remove access or reverse the item for CRA strategist under Fair Lending.
• Appraisal-gap outcomes in majority-minority tracts shows a one-file miss after an exception rate twice as high for one group after credit controls, not a Pricing and Credit Limits program failure.
• Appraisal-gap outcomes in majority-minority tracts cannot decide dealer overlays introduce prohibited yet after an exception rate twice as high for one group after credit controls; hold is the only Fair Lending close a manufactured-housing lender with dealer-originated files can defend.

Analysis required

• Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls.
• Flag any disparate-impact table CRA strategist cannot explain from appraisal-gap outcomes in majority-minority tracts.
• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• For this Fair Lending Pricing and Credit Limits file, read appraisal-gap outcomes in majority-minority tracts 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.