Whether a redlining pattern exists after controls from mortgage pricing

Situation

Mortgage pricing residual by prohibited-basis group arrived with a branch that stopped taking applications in one ZIP for exam-response coordinator. That is a Fair Lending Pricing and Credit Limits decision on a redlining pattern exists in an institution preparing for a redlining exam.

Decision

Exam-response coordinator in an institution preparing for a redlining exam 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 branch that stopped taking applications in one ZIP.

Hypotheses to test

• A branch that stopped taking applications in one ZIP is noise around an already-controlled Pricing and Credit Limits process in an institution preparing for a redlining exam, given mortgage pricing residual by prohibited-basis group.
• A branch that stopped taking applications in one ZIP is the event in mortgage pricing residual by prohibited-basis group that forces Remove access or reverse the item for exam-response coordinator under Fair Lending.
• Mortgage pricing residual by prohibited-basis group shows a one-file miss after a branch that stopped taking applications in one ZIP, not a Pricing and Credit Limits program failure.
• Mortgage pricing residual by prohibited-basis group cannot decide a redlining pattern exists yet after a branch that stopped taking applications in one ZIP; hold is the only Fair Lending close an institution preparing for a redlining exam can defend.

Analysis required

• Check HMDA coding and underwriting policy against a redlining pattern exists.
• Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP.
• Flag any disparate-impact table exam-response coordinator 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 branch that stopped taking applications in one ZIP and write the one fact that would move a redlining pattern exists for exam-response coordinator.

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 (mortgage pricing residual by prohibited-basis group after a branch that stopped taking applications in one ZIP). The follow-on Pricing and Credit Limits action is what exam-response coordinator does next: implement the option, assign an owner, and log the missing fact.