Assess whether pricing disparities are justified by legitimate factors

SITUATION The working file is HMDA LAR validity and quality edits after a branch that stopped taking applications in one ZIP. CRA strategist in a mortgage company after a pricing-regression spike has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs file.

DECISION CRA strategist in a mortgage company after a pricing-regression spike 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 branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. HMDA LAR validity and quality edits reads as Remove access or reverse the item once a branch that stopped taking applications in one ZIP is lined up to the same Fair Lending population. 2. HMDA LAR validity and quality edits is closer to Temporary compensating control after a branch that stopped taking applications in one ZIP; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract. 3. Approve a documented exception is still live in HMDA LAR validity and quality edits for CRA strategist in a mortgage company after a pricing-regression spike. 4. HMDA LAR validity and quality edits is missing the fact CRA strategist needs after a branch that stopped taking applications in one ZIP; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in HMDA LAR validity and quality edits. 2. Check HMDA coding and underwriting policy against pricing disparities are justified. 3. Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP. 4. For this Fair Lending CRA and Special-Purpose Programs file, read HMDA LAR validity and quality edits against a branch that stopped taking applications in one ZIP 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 / CRA and Special-Purpose Programs packet (HMDA LAR validity and quality edits after a branch that stopped taking applications in one ZIP). If HMDA LAR validity and quality edits cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If HMDA LAR validity and quality edits after a branch that stopped taking applications in one ZIP cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, CRA strategist must do not infer a control or scheme beyond the transaction and entitlement evidence.