Assess whether dealer overlays introduce prohibited steering (8e6543)

SITUATION Pricing and Credit Limits work in a mortgage company after a pricing-regression spike now turns on dealer overlays introduce prohibited because a SPCP that originated almost no loans to the intended class put manufactured-housing dealer overlay notes in play. Fair-lending officer should say what manufactured-housing dealer overlay notes 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 manufactured-housing dealer overlay notes after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. A SPCP that originated almost no loans to the intended class is noise around an already-controlled Pricing and Credit Limits process in a mortgage company after a pricing-regression spike, given manufactured-housing dealer overlay notes. 2. A SPCP that originated almost no loans to the intended class is the event in manufactured-housing dealer overlay notes that forces Remove access or reverse the item for fair-lending officer under Fair Lending. 3. Manufactured-housing dealer overlay notes shows a one-file miss after a SPCP that originated almost no loans to the intended class, not a Pricing and Credit Limits program failure. 4. Manufactured-housing dealer overlay notes cannot decide dealer overlays introduce prohibited yet after a SPCP that originated almost no loans to the intended class; hold is the only Fair Lending close a mortgage company after a pricing-regression spike can defend.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend. 2. Match the adverse-action language to the facts in manufactured-housing dealer overlay notes. 3. Check HMDA coding and underwriting policy against dealer overlays introduce prohibited. 4. For this Fair Lending Pricing and Credit Limits file, read manufactured-housing dealer overlay notes 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 fair-lending officer.

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 (manufactured-housing dealer overlay notes after a SPCP that originated almost no loans to the intended class). Lead with the Fair Lending option manufactured-housing dealer overlay notes can support after a SPCP that originated almost no loans to the intended class, then the two facts that force it, then the Monday action for fair-lending officer in a mortgage company after a pricing-regression spike.