Assess whether pricing disparities are justified by legitimate factors

SITUATION Appraisal-gap outcomes in majority-minority tracts arrived with a DOJ or CFPB monitor request for pricing files. Community-development lender in a manufactured-housing lender with dealer-originated files still has an evidence gap on whether pricing disparities are justified by legitimate factors.

DECISION Community-development lender in a manufactured-housing lender with dealer-originated files must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using appraisal-gap outcomes in majority-minority tracts after a DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. The population in appraisal-gap outcomes in majority-minority tracts is the one a DOJ or CFPB monitor request for pricing files named, so Remove access or reverse the item follows for this Examination and Notices file. 2. The population in appraisal-gap outcomes in majority-minority tracts is adjacent only to a DOJ or CFPB monitor request for pricing files; Temporary compensating control is the honest Fair Lending call. 3. A manufactured-housing lender with dealer-originated files already contained a DOJ or CFPB monitor request for pricing files before appraisal-gap outcomes in majority-minority tracts arrived; no new Examination and Notices path. 4. Provenance on appraisal-gap outcomes in majority-minority tracts after a DOJ or CFPB monitor request for pricing files is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 2. Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts. 3. Check HMDA coding and underwriting policy against pricing disparities are justified. 4. For this Fair Lending Examination and Notices file, read appraisal-gap outcomes in majority-minority tracts against a DOJ or CFPB monitor request for pricing files 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 / Examination and Notices packet (appraisal-gap outcomes in majority-minority tracts after a DOJ or CFPB monitor request for pricing files). If appraisal-gap outcomes in majority-minority tracts cannot force a Fair Lending label under Examination and Notices, stop. Do not invent missing evidence a manufactured-housing lender with dealer-originated files does not have.

COMMAND RETURNS - Bottom-line Fair Lending option on pricing disparities are justified, then the evidence in appraisal-gap outcomes in majority-minority tracts, then the action for community-development lender - Hypothesis scorecard against appraisal-gap outcomes in majority-minority tracts: supported / rejected / untestable - Examination and Notices finding in appraisal-gap outcomes in majority-minority tracts that a second reviewer can re-perform - Missing page in appraisal-gap outcomes in majority-minority tracts after a DOJ or CFPB monitor request for pricing files, if any