Whether dealer overlays introduce prohibited steering from mortgage pricing

Situation

A DOJ or CFPB monitor request for pricing files put mortgage pricing residual by prohibited-basis group in front of CRA strategist in a manufactured-housing lender with dealer-originated files. This Fair Lending / Pricing and Credit Limits close is dealer overlays introduce prohibited from mortgage pricing residual by prohibited-basis group, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

CRA strategist 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 mortgage pricing residual by prohibited-basis group after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• Authorize Remove access or reverse the item now; mortgage pricing residual by prohibited-basis group already has the discriminator after a DOJ or CFPB monitor request for pricing files.
• Keep Temporary compensating control in force until mortgage pricing residual by prohibited-basis group is completed after a DOJ or CFPB monitor request for pricing files for CRA strategist.
• Treat mortgage pricing residual by prohibited-basis group as Approve a documented exception because both readings appear after a DOJ or CFPB monitor request for pricing files.
• Refuse a Fair Lending close: CRA strategist does not have the page dealer overlays introduce prohibited turns on in mortgage pricing residual by prohibited-basis group.

Analysis required

• Check HMDA coding and underwriting policy against dealer overlays introduce prohibited.
• Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files.
• Flag any disparate-impact table CRA strategist 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 DOJ or CFPB monitor request for pricing files and write the one fact that would move dealer overlays introduce prohibited for CRA strategist.

Recommendation