Assess whether pricing disparities are justified by legitimate factors

SITUATION Redlining and HMDA Data work in a bank with thin HMDA LAR quality now turns on pricing disparities are justified because an exception rate twice as high for one group after credit controls put manufactured-housing dealer overlay notes in play. Exam-response coordinator should say what manufactured-housing dealer overlay notes proves.

DECISION Exam-response coordinator 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 manufactured-housing dealer overlay notes after an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. The population in manufactured-housing dealer overlay notes is the one an exception rate twice as high for one group after credit controls named, so Remove access or reverse the item follows for this Redlining and HMDA Data file. 2. The population in manufactured-housing dealer overlay notes is adjacent only to an exception rate twice as high for one group after credit controls; Temporary compensating control is the honest Fair Lending call. 3. A bank with thin HMDA LAR quality already contained an exception rate twice as high for one group after credit controls before manufactured-housing dealer overlay notes arrived; no new Redlining and HMDA Data path. 4. Provenance on manufactured-housing dealer overlay notes after an exception rate twice as high for one group after credit controls is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against pricing disparities are justified. 2. Compare manufactured-housing dealer overlay notes 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 exam-response coordinator cannot explain from manufactured-housing dealer overlay notes. 4. For this Fair Lending Redlining and HMDA Data file, read manufactured-housing dealer overlay notes 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 exam-response coordinator.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Redlining and HMDA Data packet (manufactured-housing dealer overlay notes after an exception rate twice as high for one group after credit controls). Lead with the Fair Lending option manufactured-housing dealer overlay notes 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 exam-response coordinator in a bank with thin HMDA LAR quality.