Whether notices match the actual decisioning reasons from mortgage pricing

Situation

Pricing and Credit Limits work in a mortgage company after a pricing-regression spike now turns on notices match the actual because a CRA PE that called the assessment area too narrow put mortgage pricing residual by prohibited-basis group in play. Fair-lending officer should say what mortgage pricing residual by prohibited-basis group proves.

Decision

Fair-lending officer 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 mortgage pricing residual by prohibited-basis group after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• Fair-lending officer can defend Remove access or reverse the item from mortgage pricing residual by prohibited-basis group after a CRA PE that called the assessment area too narrow in a Fair Lending challenge.
• Fair-lending officer cannot defend Remove access or reverse the item from mortgage pricing residual by prohibited-basis group; Temporary compensating control is what the extract actually supports after a CRA PE that called the assessment area too narrow.
• A CRA PE that called the assessment area too narrow never reached the population in mortgage pricing residual by prohibited-basis group — reopen intake, do not close notices match the actual.
• Two facts in mortgage pricing residual by prohibited-basis group after a CRA PE that called the assessment area too narrow conflict for fair-lending officer; hold this Pricing and Credit Limits file.

Analysis required

• Check HMDA coding and underwriting policy against notices match the actual.
• Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow.
• Flag any disparate-impact table fair-lending officer cannot explain from mortgage pricing residual by prohibited-basis group.
• For this Fair Lending Pricing and Credit Limits file, read mortgage pricing residual by prohibited-basis group against a CRA PE that called the assessment area too narrow and write the one fact that would move notices match the actual for fair-lending officer.

Recommendation