Assess whether pricing disparities are justified by legitimate factors

SITUATION Community-development lender is responsible for pricing disparities are justified in a manufactured-housing lender, using dealer-originated files with model-reason-code mapping that does not match notices as the only working extract. A CRA PE that called the assessment area too narrow is what reset the timeline for this Fair Lending Examination and Notices file.

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 model-reason-code mapping that does not match notices after a CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; model-reason-code mapping that does not match notices already has the discriminator after a CRA PE that called the assessment area too narrow. 2. Keep Temporary compensating control in force until model-reason-code mapping that does not match notices is completed after a CRA PE that called the assessment area too narrow for community-development lender. 3. Treat model-reason-code mapping that does not match notices as Approve a documented exception because both readings appear after a CRA PE that called the assessment area too narrow. 4. Refuse a Fair Lending close: community-development lender does not have the decision pricing disparities are justified turns on in model-reason-code mapping that does not match notices.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in model-reason-code mapping that does not match notices. 2. Check HMDA coding and underwriting policy against pricing disparities are justified. 3. Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow. 4. For this Fair Lending Examination and Notices file, read model-reason-code mapping that does not match notices against a CRA PE that called the assessment area too narrow 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 (model-reason-code mapping that does not match notices after a CRA PE that called the assessment area too narrow). Lead with the Fair Lending option model-reason-code mapping that does not match notices can support after a CRA PE that called the assessment area too narrow, then the two facts that force it, then the Monday action for community-development lender in a manufactured-housing lender with dealer-originated files.