Assess whether dealer overlays introduce prohibited steering (1db1c2)

Situation

A manufactured-housing lender with dealer-originated files cannot treat a SPCP that originated almost no loans to the intended class as color commentary on underwriting exception log by branch. Exam-response coordinator must close dealer overlays introduce prohibited from that extract under Fair Lending / CRA and Special-Purpose Programs.

Decision

Exam-response coordinator 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 underwriting exception log by branch after a SPCP that originated almost no loans to the intended class.

Hypotheses to test

• Exam-response coordinator can defend Remove access or reverse the item from underwriting exception log by branch after a SPCP that originated almost no loans to the intended class in a Fair Lending challenge.
• Exam-response coordinator cannot defend Remove access or reverse the item from underwriting exception log by branch; Temporary compensating control is what the extract actually supports after a SPCP that originated almost no loans to the intended class.
• A SPCP that originated almost no loans to the intended class never reached the population in underwriting exception log by branch — reopen intake, do not close dealer overlays introduce prohibited.
• Two facts in underwriting exception log by branch after a SPCP that originated almost no loans to the intended class conflict for exam-response coordinator; hold this CRA and Special-Purpose Programs file.

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 a manufactured-housing lender with dealer-originated files must defend.
• Match the adverse-action language to the facts in underwriting exception log by branch.
• For this Fair Lending CRA and Special-Purpose Programs file, read underwriting exception log by branch against a SPCP that originated almost no loans to the intended class 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 / CRA and Special-Purpose Programs packet (underwriting exception log by branch after a SPCP that originated almost no loans to the intended class). If underwriting exception log by branch cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If underwriting exception log by branch after a SPCP that originated almost no loans to the intended class cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, exam-response coordinator must do not infer a control or scheme beyond the transaction and entitlement evidence.