Assess whether pricing disparities are justified by legitimate factors

SITUATION Adverse-action notice operations lead is responsible for pricing disparities are justified in a lender expanding into majority-minority census tracts, using geographic application and origination heat map as the only working extract. A SPCP that originated almost no loans to the intended class is what reset the timeline for this Fair Lending Redlining and HMDA Data file.

DECISION Adverse-action notice operations lead in a lender expanding into majority-minority census tracts must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using geographic application and origination heat map after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. A SPCP that originated almost no loans to the intended class is noise around an already-controlled Redlining and HMDA Data process in a lender expanding into majority-minority census tracts, given geographic application and origination heat map. 2. A SPCP that originated almost no loans to the intended class is the event in geographic application and origination heat map that forces Remove access or reverse the item for adverse-action notice operations lead under Fair Lending. 3. Geographic application and origination heat map shows a one-file miss after a SPCP that originated almost no loans to the intended class, not a Redlining and HMDA Data program failure. 4. Geographic application and origination heat map cannot decide pricing disparities are justified yet after a SPCP that originated almost no loans to the intended class; hold is the only Fair Lending close a lender expanding into majority-minority census tracts can defend.

ANALYSIS REQUIRED 1. Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class. 2. Flag any disparate-impact table adverse-action notice operations lead cannot explain from geographic application and origination heat map. 3. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 4. For this Fair Lending Redlining and HMDA Data file, read geographic application and origination heat map against a SPCP that originated almost no loans to the intended class and write the one fact that would move pricing disparities are justified for adverse-action notice operations lead.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (geographic application and origination heat map after a SPCP that originated almost no loans to the intended class). If geographic application and origination heat map cannot force a Fair Lending label under Redlining and HMDA Data, stop. If geographic application and origination heat map after a SPCP that originated almost no loans to the intended class cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Redlining and HMDA Data close, adverse-action notice operations lead must do not infer a control or scheme beyond the transaction and entitlement evidence.