Assess whether dealer overlays introduce prohibited steering from mortgage

SITUATION Mortgage pricing residual by prohibited-basis group arrived with a CRA PE that called the assessment area too narrow. Fair-lending officer in a mortgage company after a pricing-regression spike still has an evidence gap on whether dealer overlays introduce prohibited steering.

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 mortgage pricing residual by prohibited-basis group after a CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. The population in mortgage pricing residual by prohibited-basis group is the one a CRA PE that called the assessment area too narrow named, so Remove access or reverse the item follows for this Pricing and Credit Limits file. 2. The population in mortgage pricing residual by prohibited-basis group is adjacent only to a CRA PE that called the assessment area too narrow; Temporary compensating control is the honest Fair Lending call. 3. A mortgage company after a pricing-regression spike already contained a CRA PE that called the assessment area too narrow before mortgage pricing residual by prohibited-basis group arrived; no new Pricing and Credit Limits path. 4. Provenance on mortgage pricing residual by prohibited-basis group after a CRA PE that called the assessment area too narrow is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow. 2. Flag any disparate-impact table fair-lending officer cannot explain from mortgage pricing residual by prohibited-basis group. 3. Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend. 4. For this Fair Lending Pricing and Credit Limits file, read mortgage pricing residual by prohibited-basis group against a CRA PE that called the assessment area too narrow 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 (mortgage pricing residual by prohibited-basis group after a CRA PE that called the assessment area too narrow). If mortgage pricing residual by prohibited-basis group cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent missing evidence a mortgage company after a pricing-regression spike does not have.