In that context, let me focus on how your pricing policies might be addressed. Most mortgage lenders have stated policies that they do not discriminate against any prohibited class of borrowers. It is the role of the CEO and senior management to ensure that procedures and controls throughout the organization support those policies. Start by evaluating compensation arrangements for your loan originators.
This is particularly important for institutions in which the ultimate price of a loan may be set at the discretion of individual loan officers or branch managers, or on some other decentralized basis-- especially if the individual setting the price receives some share of any price over a certain floor or "par" rate.