Dealer Overlays Introduce Prohibited Steering — Mortgage Company

Situation

A mortgage company after a pricing-regression spike cannot treat a board asking if the bank should settle a matched-pair study as color commentary on HMDA LAR validity and quality edits. Fair-lending officer must close dealer overlays introduce prohibited from that extract under Fair Lending / Pricing and Credit Limits.

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 HMDA LAR validity and quality edits after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• HMDA LAR validity and quality edits reads as Remove access or reverse the item once a board asking if the bank should settle a matched-pair study is lined up to the same Fair Lending population.
• HMDA LAR validity and quality edits is closer to Temporary compensating control after a board asking if the bank should settle a matched-pair study; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract.
• Approve a documented exception is still live in HMDA LAR validity and quality edits for fair-lending officer in a mortgage company after a pricing-regression spike.
• HMDA LAR validity and quality edits is missing the fact fair-lending officer needs after a board asking if the bank should settle a matched-pair study; stop this Fair Lending close.

Analysis required

• Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study.
• Flag any disparate-impact table fair-lending officer cannot explain from HMDA LAR validity and quality edits.
• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• For this Fair Lending Pricing and Credit Limits file, read HMDA LAR validity and quality edits against a board asking if the bank should settle a matched-pair study 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 (HMDA LAR validity and quality edits after a board asking if the bank should settle a matched-pair study). Lead with the Fair Lending option HMDA LAR validity and quality edits can support after a board asking if the bank should settle a matched-pair study, then the two facts that force it, then the Monday action for fair-lending officer in a mortgage company after a pricing-regression spike.