Assess whether pricing disparities are justified by legitimate factors

SITUATION A marketing mailer that skipped majority-minority tracts put manufactured-housing dealer overlay notes in front of fair-lending officer in a manufactured-housing lender with dealer-originated files. This Fair Lending / Redlining and HMDA Data close is pricing disparities are justified from manufactured-housing dealer overlay notes, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

DECISION Fair-lending officer in a manufactured-housing lender with dealer-originated files must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using manufactured-housing dealer overlay notes after a marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. Fair-lending officer can defend Remove access or reverse the item from manufactured-housing dealer overlay notes after a marketing mailer that skipped majority-minority tracts in a Fair Lending challenge. 2. Fair-lending officer cannot defend Remove access or reverse the item from manufactured-housing dealer overlay notes; Temporary compensating control is what the extract actually supports after a marketing mailer that skipped majority-minority tracts. 3. A marketing mailer that skipped majority-minority tracts never reached the population in manufactured-housing dealer overlay notes — reopen intake, do not close pricing disparities are justified. 4. Two facts in manufactured-housing dealer overlay notes after a marketing mailer that skipped majority-minority tracts conflict for fair-lending officer; hold this Redlining and HMDA Data file.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 2. Match the adverse-action language to the facts in manufactured-housing dealer overlay notes. 3. Check HMDA coding and underwriting policy against pricing disparities are justified. 4. For this Fair Lending Redlining and HMDA Data file, read manufactured-housing dealer overlay notes against a marketing mailer that skipped majority-minority tracts 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 / Redlining and HMDA Data packet (manufactured-housing dealer overlay notes after a marketing mailer that skipped majority-minority tracts). The follow-on Redlining and HMDA Data action is what fair-lending officer does next: implement the option, assign an owner, and log the missing fact.