Assess whether pricing disparities are justified by legitimate factors

SITUATION Fair-lending officer is responsible for pricing disparities are justified in an institution preparing for a redlining exam, using geographic application and origination heat map as the only working extract. A CRA PE that called the assessment area too narrow is what reset the timeline for this Fair Lending Examination and Notices file.

DECISION Fair-lending officer in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using geographic application and origination heat map after a CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. A CRA PE that called the assessment area too narrow is noise around an already-controlled Examination and Notices process in an institution preparing for a redlining exam, given geographic application and origination heat map. 2. A CRA PE that called the assessment area too narrow is the event in geographic application and origination heat map that forces Remove access or reverse the item for fair-lending officer under Fair Lending. 3. Geographic application and origination heat map shows a one-file miss after a CRA PE that called the assessment area too narrow, not a Examination and Notices program failure. 4. Geographic application and origination heat map cannot decide pricing disparities are justified yet after a CRA PE that called the assessment area too narrow; hold is the only Fair Lending close an institution preparing for a redlining exam can defend.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern an institution preparing for a redlining exam must defend. 2. Match the adverse-action language to the facts in geographic application and origination heat map. 3. Check HMDA coding and underwriting policy against pricing disparities are justified. 4. For this Fair Lending Examination and Notices file, read geographic application and origination heat map against a CRA PE that called the assessment area too narrow and write the one fact that would move pricing disparities are justified for fair-lending officer.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (geographic application and origination heat map after a CRA PE that called the assessment area too narrow). Lead with the Fair Lending option geographic application and origination heat map can support after a CRA PE that called the assessment area too narrow, then the two facts that force it, then the Monday action for fair-lending officer in an institution preparing for a redlining exam.