Assess whether pricing disparities are justified by legitimate factors

SITUATION A notice that cites 'other' as the principal reason 40% of the time put underwriting exception log by branch in front of HMDA data-quality manager in a credit-card issuer changing line-assignment logic. This Fair Lending / Redlining and HMDA Data close is pricing disparities are justified from underwriting exception log by branch, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

DECISION HMDA data-quality manager in a credit-card issuer changing line-assignment logic must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using underwriting exception log by branch after a notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. HMDA data-quality manager can defend Remove access or reverse the item from underwriting exception log by branch after a notice that cites 'other' as the principal reason 40% of the time in a Fair Lending challenge. 2. HMDA data-quality manager cannot defend Remove access or reverse the item from underwriting exception log by branch; Temporary compensating control is what the extract actually supports after a notice that cites 'other' as the principal reason 40% of the time. 3. A notice that cites 'other' as the principal reason 40% of the time never reached the population in underwriting exception log by branch — reopen intake, do not close pricing disparities are justified. 4. Two facts in underwriting exception log by branch after a notice that cites 'other' as the principal reason 40% of the time conflict for HMDA data-quality manager; hold this Redlining and HMDA Data file.

ANALYSIS REQUIRED 1. Flag any disparate-impact table HMDA data-quality manager cannot explain from underwriting exception log by branch. 2. Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend. 3. Match the adverse-action language to the facts in underwriting exception log by branch. 4. For this Fair Lending Redlining and HMDA Data file, read underwriting exception log by branch against a notice that cites 'other' as the principal reason 40% of the time 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 / Redlining and HMDA Data packet (underwriting exception log by branch after a notice that cites 'other' as the principal reason 40% of the time). The follow-on Redlining and HMDA Data action is what HMDA data-quality manager does next: implement the option, assign an owner, and log the missing fact.