Assess whether pricing disparities are justified by legitimate factors

SITUATION Model-reason-code mapping that does not match notices arrived with a notice that cites 'other' as the principal reason 40% of the time for CRA strategist. That is a Fair Lending CRA and Special-Purpose Programs decision on pricing disparities are justified in a mortgage company after a pricing-regression spike.

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 model-reason-code mapping that does not match notices after a notice that cites 'other' as the principal reason 40% of the time.

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 notice that cites 'other' as the principal reason 40% of the time. 2. Keep Temporary compensating control in force until model-reason-code mapping that does not match notices is completed after a notice that cites 'other' as the principal reason 40% of the time for CRA strategist. 3. Treat model-reason-code mapping that does not match notices as Approve a documented exception because both readings appear after a notice that cites 'other' as the principal reason 40% of the time. 4. Refuse a Fair Lending close: CRA strategist does not have the decision pricing disparities are justified turns on in model-reason-code mapping that does not match notices.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend. 2. Match the adverse-action language to the facts in model-reason-code mapping that does not match notices. 3. Check HMDA coding and underwriting policy against pricing disparities are justified. 4. For this Fair Lending CRA and Special-Purpose Programs file, read model-reason-code mapping that does not match notices against a notice that cites 'other' as the principal reason 40% of the time 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 (model-reason-code mapping that does not match notices after a notice that cites 'other' as the principal reason 40% of the time). Lead with the Fair Lending option model-reason-code mapping that does not match notices can support after a notice that cites 'other' as the principal reason 40% of the time, then the two facts that force it, then the Monday action for CRA strategist in a mortgage company after a pricing-regression spike.