Whether dealer overlays introduce prohibited steering from underwriting

Situation

After a community complaint about appraisal gaps, underwriting exception log by branch is what exam-response coordinator can touch in an institution preparing for a redlining exam. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Pricing and Credit Limits file.

Decision

Exam-response coordinator 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 underwriting exception log by branch after a community complaint about appraisal gaps.

Hypotheses to test

• Authorize Remove access or reverse the item now; underwriting exception log by branch already has the discriminator after a community complaint about appraisal gaps.
• Keep Temporary compensating control in force until underwriting exception log by branch is completed after a community complaint about appraisal gaps for exam-response coordinator.
• Treat underwriting exception log by branch as Approve a documented exception because both readings appear after a community complaint about appraisal gaps.
• Refuse a Fair Lending close: exam-response coordinator does not have the page dealer overlays introduce prohibited turns on in underwriting exception log by branch.

Analysis required

• Flag any disparate-impact table exam-response coordinator cannot explain from underwriting exception log by branch.
• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• Match the adverse-action language to the facts in underwriting exception log by branch.
• For this Fair Lending Pricing and Credit Limits file, read underwriting exception log by branch against a community complaint about appraisal gaps and write the one fact that would move dealer overlays introduce prohibited for exam-response coordinator.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (underwriting exception log by branch after a community complaint about appraisal gaps). Lead with the Fair Lending option underwriting exception log by branch can support after a community complaint about appraisal gaps, then the two facts that force it, then the Monday action for exam-response coordinator in an institution preparing for a redlining exam.