Assess whether pricing disparities are justified by legitimate factors

SITUATION HMDA LAR validity and quality edits arrived with a marketing mailer that skipped majority-minority tracts for adverse-action notice operations lead. That is a Fair Lending CRA and Special-Purpose Programs decision on pricing disparities are justified in a small-business desk using a new vendor score.

DECISION Adverse-action notice operations lead in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using HMDA LAR validity and quality edits after a marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. The population in HMDA LAR validity and quality edits is the one a marketing mailer that skipped majority-minority tracts named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file. 2. The population in HMDA LAR validity and quality edits is adjacent only to a marketing mailer that skipped majority-minority tracts; Temporary compensating control is the honest Fair Lending call. 3. A small-business desk using a new vendor score already contained a marketing mailer that skipped majority-minority tracts before HMDA LAR validity and quality edits arrived; no new CRA and Special-Purpose Programs path. 4. Provenance on HMDA LAR validity and quality edits after a marketing mailer that skipped majority-minority tracts is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts. 2. Flag any disparate-impact table adverse-action notice operations lead cannot explain from HMDA LAR validity and quality edits. 3. Test a documented exception versus a pattern a small-business desk using a new vendor score must defend. 4. For this Fair Lending CRA and Special-Purpose Programs file, read HMDA LAR validity and quality edits against a marketing mailer that skipped majority-minority tracts 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 / CRA and Special-Purpose Programs packet (HMDA LAR validity and quality edits after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option HMDA LAR validity and quality edits can support after a marketing mailer that skipped majority-minority tracts, then the two facts that force it, then the Monday action for adverse-action notice operations lead in a small-business desk using a new vendor score.