Assess whether dealer overlays introduce prohibited steering (09298b)

Situation

A board asking if the bank should settle a matched-pair study put underwriting exception log by branch in front of CRA strategist in a mortgage company after a pricing-regression spike. This Fair Lending / CRA and Special-Purpose Programs close is dealer overlays introduce prohibited from underwriting exception log by branch, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

CRA strategist in a mortgage company after a pricing-regression spike must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using underwriting exception log by branch after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• A board asking if the bank should settle a matched-pair study is noise around an already-controlled CRA and Special-Purpose Programs process in a mortgage company after a pricing-regression spike, given underwriting exception log by branch.
• A board asking if the bank should settle a matched-pair study is the event in underwriting exception log by branch that forces Remove access or reverse the item for CRA strategist under Fair Lending.
• Underwriting exception log by branch shows a one-file miss after a board asking if the bank should settle a matched-pair study, not a CRA and Special-Purpose Programs program failure.
• Underwriting exception log by branch cannot decide dealer overlays introduce prohibited yet after a board asking if the bank should settle a matched-pair study; hold is the only Fair Lending close a mortgage company after a pricing-regression spike can defend.

Analysis required

• Match the adverse-action language to the facts in underwriting exception log by branch.
• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study.
• For this Fair Lending CRA and Special-Purpose Programs file, read underwriting exception log by branch against a board asking if the bank should settle a matched-pair study and write the one fact that would move dealer overlays introduce prohibited for CRA strategist.