Assess whether dealer overlays introduce prohibited steering (776d08)

Situation

In a mortgage company after a pricing-regression spike, appraisal-gap outcomes in majority-minority tracts is the evidence after a marketing mailer that skipped majority-minority tracts. CRA strategist has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs close using appraisal-gap outcomes in majority-minority tracts.

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 appraisal-gap outcomes in majority-minority tracts after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Authorize Remove access or reverse the item now; appraisal-gap outcomes in majority-minority tracts already has the discriminator after a marketing mailer that skipped majority-minority tracts.
• Keep Temporary compensating control in force until appraisal-gap outcomes in majority-minority tracts is completed after a marketing mailer that skipped majority-minority tracts for CRA strategist.
• Treat appraisal-gap outcomes in majority-minority tracts as Approve a documented exception because both readings appear after a marketing mailer that skipped majority-minority tracts.
• Refuse a Fair Lending close: CRA strategist does not have the page dealer overlays introduce prohibited turns on in appraisal-gap outcomes in majority-minority tracts.

Analysis required

• Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts.
• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts.
• For this Fair Lending CRA and Special-Purpose Programs file, read appraisal-gap outcomes in majority-minority tracts against a marketing mailer that skipped majority-minority tracts and write the one fact that would move dealer overlays introduce prohibited for CRA strategist.

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 (appraisal-gap outcomes in majority-minority tracts after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option appraisal-gap outcomes in majority-minority tracts can support after a marketing mailer that skipped majority-minority tracts, then the two facts that force it, then the Monday action for CRA strategist in a mortgage company after a pricing-regression spike.