Assess whether pricing disparities are justified by legitimate factors

SITUATION An institution preparing for a redlining exam cannot treat a community complaint about appraisal gaps as incidental context on HMDA LAR validity and quality edits. Community-development lender must close pricing disparities are justified from that extract under Fair Lending / CRA and Special-Purpose Programs.

DECISION Community-development lender in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using HMDA LAR validity and quality edits after a community complaint about appraisal gaps.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; HMDA LAR validity and quality edits already has the discriminator after a community complaint about appraisal gaps. 2. Keep Temporary compensating control in force until HMDA LAR validity and quality edits is completed after a community complaint about appraisal gaps for community-development lender. 3. Treat HMDA LAR validity and quality edits as Approve a documented exception because both readings appear after a community complaint about appraisal gaps. 4. Refuse a Fair Lending close: community-development lender does not have the decision pricing disparities are justified turns on in HMDA LAR validity and quality edits.

ANALYSIS REQUIRED 1. Flag any disparate-impact table community-development lender cannot explain from HMDA LAR validity and quality edits. 2. Test a documented exception versus a pattern an institution preparing for a redlining exam must defend. 3. Match the adverse-action language to the facts in HMDA LAR validity and quality edits. 4. For this Fair Lending CRA and Special-Purpose Programs file, read HMDA LAR validity and quality edits against a community complaint about appraisal gaps and write the one fact that would move pricing disparities are justified for community-development lender.

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 (HMDA LAR validity and quality edits after a community complaint about appraisal gaps). Lead with the Fair Lending option HMDA LAR validity and quality edits can support after a community complaint about appraisal gaps, then the two facts that force it, then the Monday action for community-development lender in an institution preparing for a redlining exam.

COMMAND RETURNS - Bottom-line Fair Lending option on pricing disparities are justified, then the evidence in HMDA LAR validity and quality edits, then the action for community-development lender - Hypothesis scorecard against HMDA LAR validity and quality edits: supported / rejected / untestable - Named option among Remove access or reverse the item, Temporary compensating control, Approve a documented exception and the fact that kills the others - Owner and next date for community-development lender in an institution preparing for a redlining exam