Three-eighths more in rate and three-quarters of a point more in fees separate two matched borrowers, a difference MT431's Unit 9 fair lending memo tests under three federal statutes. Searches like "mt 431 unit 9 assignment example", "mt431 unit 9 sample" and "mt431 unit 9 example" land here.
What a finished MT431 Unit 9 fair lending memo looks like
A four-page memo to the lender's compliance officer, in the order facts, issue, law, analysis and recommendation. Two files share one comparison table: income, credit score, loan-to-value, ratios, rate, points, APR and the HMDA rate spread against a bracketed average prime offer rate. Applicant B's income appears twice, since the loan officer's worksheet left out $1,150 of monthly child support and showed a 43.9 percent ratio where the full figure gives 37.1, against Applicant A's 37.3. The law section states each statute with its year and regulation: the Equal Credit Opportunity Act of 1974 and Regulation B, the Fair Housing Act, enacted in 1968 and amended in 1988, and the Home Mortgage Disclosure Act of 1975 and Regulation C. The recommendation runs to four actions.
How a MT431 Unit 9 example is structured
The memo proceeds from comparison to law rather than the reverse, because fair lending review in practice begins with matched files that should have been treated alike. The table therefore comes before any statute. Once the gap is priced, $7,695 over a five-year horizon, the memo separates what each law contributes. ECOA and Regulation B supply the bases relevant here, sex and marital status, along with the specific bar on discounting income because it comes from child support. The Fair Housing Act adds familial status and reaches the terms of residential loans. HMDA prohibits nothing, but its rate spread and points fields are exactly where a pattern like this surfaces for examiners. The analysis weighs the loan officer's stated reason, a risk judgment, against files showing equal income, a higher score for Applicant B and matching ratios once her full income counts.
Two files, one table
Income, scores, loan-to-value, ratios, rate, points, APR and rate spread for both applicants, with the child support line shown both ways.
The gap in dollars
$72.59 more each month and $2,190 more at closing, about $7,695 over five years and $28,324 across the full term.
Three statutes, three jobs
ECOA and Regulation B on sex, marital status and support income; the Fair Housing Act on familial status and loan terms; HMDA on the data exposing both.
Testing the stated reason
The loan officer's risk rationale set against files in which Applicant B held the higher score and, counted correctly, the same ratio.
Four remediation steps
Repricing Applicant B's loan, a lookback across the loan officer's recent files, documented limits on pricing exceptions, and income-handling training.
Where marks go in MT431 Unit 9
Precision about which statute covers which basis earns the most here. Memos that list race, sex, disability and marital status as if one law protected all of them blur ECOA and the Fair Housing Act, and graders frequently mark that down, since marital status appears only in the first and familial status only in the second. Describing HMDA as an anti-discrimination law is a similar error; it is a reporting statute whose data regulators screen. Credit follows a priced comparison of matched files rather than an assertion that terms differed. Instructors often expect the child support rule in Regulation B to be cited specifically. The recommendation should address the pattern as well as the one borrower, because a single repricing leaves untouched the discretion that produced it.
Get a MT431 Unit 9 example written to your instructions
Two applicant files or a fact pattern, the memo format expected and the rubric are enough for Unit 9. The free first fair lending memo, back within 24-48h, prices the difference between borrowers, assigns each protected basis to the statute that actually covers it, and closes with remediation aimed at the pattern.
MT431 Unit 9 questions, answered
How do ECOA and the Fair Housing Act differ?
ECOA covers all credit, not just housing, and protects bases including race, color, religion, national origin, sex, marital status, age and receipt of public assistance income. The Fair Housing Act covers housing and residential lending and protects race, color, religion, sex, national origin, disability and familial status. A mortgage case can raise both, on different bases.
Can a lender ignore child support income?
Regulation B bars a creditor from discounting or excluding income because it comes from alimony, child support or separate maintenance. The lender may still consider whether the payments are likely to continue, for example by reviewing the court order and payment history. Excluding the income without that assessment, as in the sample, is the problem the memo identifies.
Does the MT431 memo need to prove the loan officer intended to discriminate?
Not necessarily. Disparate treatment can be shown by comparing similarly qualified applicants who received different terms, with intent inferred from the pattern and the weakness of the stated reason. Disparate impact, a separate theory, targets neutral policies with unjustified discriminatory effects. State which theory your analysis relies on and why. Matched-file comparisons of the kind in the sample support disparate treatment most directly.