Assess whether pricing disparities are justified by legitimate factors

SITUATION After a HMDA resubmission that still fails quality edits, adverse-action notice principal-reason sample is what HMDA data-quality manager can touch in a credit union rolling out a special-purpose credit program. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this CRA and Special-Purpose Programs file.

DECISION HMDA data-quality manager in a credit union rolling out a special-purpose credit program must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using adverse-action notice principal-reason sample after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. The population in adverse-action notice principal-reason sample is the one a HMDA resubmission that still fails quality edits named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file. 2. The population in adverse-action notice principal-reason sample is adjacent only to a HMDA resubmission that still fails quality edits; Temporary compensating control is the honest Fair Lending call. 3. A credit union rolling out a special-purpose credit program already contained a HMDA resubmission that still fails quality edits before adverse-action notice principal-reason sample arrived; no new CRA and Special-Purpose Programs path. 4. Provenance on adverse-action notice principal-reason sample after a HMDA resubmission that still fails quality edits is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Flag any disparate-impact table HMDA data-quality manager cannot explain from adverse-action notice principal-reason sample. 2. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 3. Match the adverse-action language to the facts in adverse-action notice principal-reason sample. 4. For this Fair Lending CRA and Special-Purpose Programs file, read adverse-action notice principal-reason sample against a HMDA resubmission that still fails quality edits and write the one fact that would move pricing disparities are justified for HMDA data-quality manager.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (adverse-action notice principal-reason sample after a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option adverse-action notice principal-reason sample can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for HMDA data-quality manager in a credit union rolling out a special-purpose credit program.