Assess whether pricing disparities are justified by legitimate factors

SITUATION After an exception rate twice as high for one group after credit controls, underwriting exception log by branch is what CRA strategist can touch in a bank with thin HMDA LAR quality. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this 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 underwriting exception log by branch after an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. If Check HMDA coding and underwriting policy against pricing disparities are justified. holds, underwriting exception log by branch after an exception rate twice as high for one group after credit controls is Remove access or reverse the item for pricing disparities are justified in a bank with thin HMDA LAR quality. 2. If Check HMDA coding and underwriting policy against pricing disparities are justified. fails, CRA strategist should take Temporary compensating control on this Fair Lending Examination and Notices packet. 3. Choose Remove access or reverse the item / Temporary compensating control / Approve a docu is premature unless underwriting exception log by branch after an exception rate twice as high for one group after credit controls names the owner for pricing disparities are justified. 4. Underwriting exception log by branch is silent on the Examination and Notices discriminator after an exception rate twice as high for one group after credit controls; CRA strategist should not invent a Fair Lending label.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against pricing disparities are justified. 2. Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls. 3. Flag any disparate-impact table CRA strategist cannot explain from underwriting exception log by branch. 4. For this Fair Lending Examination and Notices file, read underwriting exception log by branch against an exception rate twice as high for one group after credit controls 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 (underwriting exception log by branch after an exception rate twice as high for one group after credit controls). Lead with the Fair Lending option underwriting exception log by branch can support after an exception rate twice as high for one group after credit controls, then the two facts that force it, then the Monday action for CRA strategist in a bank with thin HMDA LAR quality.