Assess whether pricing disparities are justified by legitimate factors

SITUATION Pricing and Credit Limits work in a mortgage company after a pricing-regression spike now turns on pricing disparities are justified because an exception rate twice as high for one group after credit controls put model-reason-code mapping that does not match notices in play. Fair-lending officer should say what model-reason-code mapping that does not match notices proves.

DECISION Fair-lending officer 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 an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. Model-reason-code mapping that does not match notices reads as Remove access or reverse the item once an exception rate twice as high for one group after credit controls is lined up to the same Fair Lending population. 2. Model-reason-code mapping that does not match notices is closer to Temporary compensating control after an exception rate twice as high for one group after credit controls; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract. 3. Approve a documented exception is still live in model-reason-code mapping that does not match notices for fair-lending officer in a mortgage company after a pricing-regression spike. 4. Model-reason-code mapping that does not match notices is missing the fact fair-lending officer needs after an exception rate twice as high for one group after credit controls; stop this Fair Lending close.

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 Pricing and Credit Limits file, read model-reason-code mapping that does not match notices 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 fair-lending officer.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (model-reason-code mapping that does not match notices after an exception rate twice as high for one group after credit controls). If model-reason-code mapping that does not match notices cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent missing evidence a mortgage company after a pricing-regression spike does not have.