Assess whether pricing disparities are justified by legitimate factors

SITUATION A small-business desk using a new vendor score cannot treat a HMDA resubmission that still fails quality edits as incidental context on mortgage pricing residual by prohibited-basis group. HMDA data-quality manager must close pricing disparities are justified from that extract under Fair Lending / Examination and Notices.

DECISION HMDA data-quality manager in a small-business desk using a new vendor score must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using mortgage pricing residual by prohibited-basis group after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. Mortgage pricing residual by prohibited-basis group lines up with a HMDA resubmission that still fails quality edits for Remove access or reverse the item on pricing disparities are justified; HMDA data-quality manager in a small-business desk using a new vendor score can execute that path. 2. Mortgage pricing residual by prohibited-basis group conflicts with a HMDA resubmission that still fails quality edits for Remove access or reverse the item, so Temporary compensating control is the Fair Lending move on this Examination and Notices packet. 3. Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason would move pricing disparities are justified only if it appears in mortgage pricing residual by prohibited-basis group after a HMDA resubmission that still fails quality edits. 4. HMDA data-quality manager should treat mortgage pricing residual by prohibited-basis group as incomplete for pricing disparities are justified rather than borrow a label from another a small-business desk using a new vendor score file.

ANALYSIS REQUIRED 1. Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits. 2. Flag any disparate-impact table HMDA data-quality manager cannot explain from mortgage pricing residual by prohibited-basis group. 3. Test a documented exception versus a pattern a small-business desk using a new vendor score must defend. 4. For this Fair Lending Examination and Notices file, read mortgage pricing residual by prohibited-basis group 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 / Examination and Notices packet (mortgage pricing residual by prohibited-basis group after a HMDA resubmission that still fails quality edits). The follow-on Examination and Notices action is what HMDA data-quality manager does next: implement the option, assign an owner, and log the missing fact.