HMDA data-quality manager must resolve whether pricing disparities are

Situation

HMDA data-quality manager owns pricing disparities are justified inside a lender expanding into majority-minority census tracts with small-business decline comparative file set as the only packet. A SPCP that originated almost no loans to the intended class is what changed the clock for this Fair Lending Pricing and Credit Limits file.

Decision

HMDA data-quality manager in a lender expanding into majority-minority census tracts must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using small-business decline comparative file set after a SPCP that originated almost no loans to the intended class.

Hypotheses to test

• HMDA data-quality manager can defend Remove access or reverse the item from small-business decline comparative file set after a SPCP that originated almost no loans to the intended class in a Fair Lending challenge.
• HMDA data-quality manager cannot defend Remove access or reverse the item from small-business decline comparative file set; Temporary compensating control is what the extract actually supports after a SPCP that originated almost no loans to the intended class.
• A SPCP that originated almost no loans to the intended class never reached the population in small-business decline comparative file set — reopen intake, do not close pricing disparities are justified.
• Two facts in small-business decline comparative file set after a SPCP that originated almost no loans to the intended class conflict for HMDA data-quality manager; hold this Pricing and Credit Limits file.

Analysis required

• Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class.
• Flag any disparate-impact table HMDA data-quality manager cannot explain from small-business decline comparative file set.
• Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend.
• For this Fair Lending Pricing and Credit Limits file, read small-business decline comparative file set against a SPCP that originated almost no loans to the intended class and write the one fact that would move pricing disparities are justified for HMDA data-quality manager.

Recommendation