Assess whether pricing disparities are justified by legitimate factors

SITUATION After a marketing mailer that skipped majority-minority tracts, underwriting exception log by branch is what community-development lender can touch in an institution preparing for a redlining exam. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this CRA and Special-Purpose Programs file.

DECISION Community-development lender in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using underwriting exception log by branch after a marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. Community-development lender can defend Remove access or reverse the item from underwriting exception log by branch after a marketing mailer that skipped majority-minority tracts in a Fair Lending challenge. 2. Community-development lender cannot defend Remove access or reverse the item from underwriting exception log by branch; Temporary compensating control is what the extract actually supports after a marketing mailer that skipped majority-minority tracts. 3. A marketing mailer that skipped majority-minority tracts never reached the population in underwriting exception log by branch — reopen intake, do not close pricing disparities are justified. 4. Two facts in underwriting exception log by branch after a marketing mailer that skipped majority-minority tracts conflict for community-development lender; hold this CRA and Special-Purpose Programs file.

ANALYSIS REQUIRED 1. Compare underwriting exception log by branch 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 community-development lender cannot explain from underwriting exception log by branch. 3. Test a documented exception versus a pattern an institution preparing for a redlining exam must defend. 4. For this Fair Lending CRA and Special-Purpose Programs file, read underwriting exception log by branch against a marketing mailer that skipped majority-minority tracts and write the one fact that would move pricing disparities are justified for community-development lender.

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 (underwriting exception log by branch after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option underwriting exception log by branch can support after a marketing mailer that skipped majority-minority tracts, then the two facts that force it, then the Monday action for community-development lender in an institution preparing for a redlining exam.