Assess whether dealer overlays introduce prohibited steering after a branch

Situation

In a small-business desk using a new vendor score, mortgage pricing residual by prohibited-basis group is the evidence after a branch that stopped taking applications in one ZIP. Second-review underwriter has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Redlining and HMDA Data close using mortgage pricing residual by prohibited-basis group.

Decision

Second-review underwriter in a small-business desk using a new vendor score 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 Redlining and HMDA Data process in a small-business desk using a new vendor score, 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 second-review underwriter 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 Redlining and HMDA Data program failure.
• Mortgage pricing residual by prohibited-basis group cannot decide dealer overlays introduce prohibited yet after a branch that stopped taking applications in one ZIP; hold is the only Fair Lending close a small-business desk using a new vendor score can defend.

Analysis required

• Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group.
• 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 branch that stopped taking applications in one ZIP.
• For this Fair Lending Redlining and HMDA Data 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 dealer overlays introduce prohibited for second-review underwriter.