Assess whether pricing disparities are justified by legitimate factors

SITUATION CRA strategist is responsible for pricing disparities are justified in a bank, using thin HMDA LAR quality with HMDA LAR validity and quality edits 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 Examination and Notices file.

DECISION CRA strategist in a bank with thin HMDA LAR quality 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 SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. HMDA LAR validity and quality edits reads as Remove access or reverse the item once a SPCP that originated almost no loans to the intended class is lined up to the same Fair Lending population. 2. HMDA LAR validity and quality edits is closer to Temporary compensating control after a SPCP that originated almost no loans to the intended class; Remove access or reverse the item would over-claim this Examination and Notices extract. 3. Approve a documented exception is still live in HMDA LAR validity and quality edits for CRA strategist in a bank with thin HMDA LAR quality. 4. HMDA LAR validity and quality edits is missing the fact CRA strategist needs after a SPCP that originated almost no loans to the intended class; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against pricing disparities are justified. 2. Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class. 3. Flag any disparate-impact table CRA strategist cannot explain from HMDA LAR validity and quality edits. 4. For this Fair Lending Examination and Notices file, read HMDA LAR validity and quality edits 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 CRA strategist.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (HMDA LAR validity and quality edits after a SPCP that originated almost no loans to the intended class). Lead with the Fair Lending option HMDA LAR validity and quality edits can support after a SPCP that originated almost no loans to the intended class, then the two facts that force it, then the Monday action for CRA strategist in a bank with thin HMDA LAR quality.

COMMAND RETURNS - Bottom-line Fair Lending option on pricing disparities are justified, then the evidence in HMDA LAR validity and quality edits, then the action for CRA strategist - Hypothesis scorecard against HMDA LAR validity and quality edits: supported / rejected / untestable - Missing page in HMDA LAR validity and quality edits after a SPCP that originated almost no loans to the intended class, if any - Regulatory or exam hook Examination and Notices would cite