Assess whether pricing disparities are justified by legitimate factors

SITUATION CRA and Special-Purpose Programs work in a credit union rolling out a special-purpose credit program now turns on pricing disparities are justified because a vendor score change with no disparate-impact test put CRA assessment-area versus lending footprint in play. HMDA data-quality manager should say what CRA assessment-area versus lending footprint proves.

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 CRA assessment-area versus lending footprint after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. CRA assessment-area versus lending footprint reads as Remove access or reverse the item once a vendor score change with no disparate-impact test is lined up to the same Fair Lending population. 2. CRA assessment-area versus lending footprint is closer to Temporary compensating control after a vendor score change with no disparate-impact test; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract. 3. Approve a documented exception is still live in CRA assessment-area versus lending footprint for HMDA data-quality manager in a credit union rolling out a special-purpose credit program. 4. CRA assessment-area versus lending footprint is missing the fact HMDA data-quality manager needs after a vendor score change with no disparate-impact test; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Flag any disparate-impact table HMDA data-quality manager cannot explain from CRA assessment-area versus lending footprint. 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 CRA assessment-area versus lending footprint. 4. For this Fair Lending CRA and Special-Purpose Programs file, read CRA assessment-area versus lending footprint against a vendor score change with no disparate-impact test 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 (CRA assessment-area versus lending footprint after a vendor score change with no disparate-impact test). If CRA assessment-area versus lending footprint cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If CRA assessment-area versus lending footprint after a vendor score change with no disparate-impact test cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, HMDA data-quality manager must do not infer a control or scheme beyond the transaction and entitlement evidence.