(RECAP: The Federal Reserve Board indicated it is scrutinizing mortgage loan pricing models that comply with Regulation Z but nonetheless, in the view of the Board, significantly increase fair lending risk. The models set a loan revenue target—based on a higher interest rate, discretionary fees, or both—that varies by mortgage loan originator (MLO). Regulators allege that setting different target prices for MLOs creates a risk of disparate impact if MLOs with higher target prices are concentrated in minority neighborhoods. While not a new theory, we expect it to feature more prominently in the CFPB and other regulators’ mortgage loan examinations and enforcement actions so long as disparate impact remains a viable basis of discrimination under fair lending laws.)