Assess whether pricing disparities are justified by legitimate factors

SITUATION In an institution preparing for a redlining exam, manufactured-housing dealer overlay notes is the evidence after a DOJ or CFPB monitor request for pricing files. Fair-lending officer has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices close using manufactured-housing dealer overlay notes.

DECISION Fair-lending officer 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 manufactured-housing dealer overlay notes after a DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; manufactured-housing dealer overlay notes already has the discriminator after a DOJ or CFPB monitor request for pricing files. 2. Keep Temporary compensating control in force until manufactured-housing dealer overlay notes is completed after a DOJ or CFPB monitor request for pricing files for fair-lending officer. 3. Treat manufactured-housing dealer overlay notes as Approve a documented exception because both readings appear after a DOJ or CFPB monitor request for pricing files. 4. Refuse a Fair Lending close: fair-lending officer does not have the decision pricing disparities are justified turns on in manufactured-housing dealer overlay notes.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against pricing disparities are justified. 2. Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files. 3. Flag any disparate-impact table fair-lending officer cannot explain from manufactured-housing dealer overlay notes. 4. For this Fair Lending Examination and Notices file, read manufactured-housing dealer overlay notes against a DOJ or CFPB monitor request for pricing files and write the one fact that would move pricing disparities are justified for fair-lending officer.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (manufactured-housing dealer overlay notes after a DOJ or CFPB monitor request for pricing files). Lead with the Fair Lending option manufactured-housing dealer overlay notes can support after a DOJ or CFPB monitor request for pricing files, then the two facts that force it, then the Monday action for fair-lending officer in an institution preparing for a redlining exam.

COMMAND RETURNS - Bottom-line Fair Lending option on pricing disparities are justified, then the evidence in manufactured-housing dealer overlay notes, then the action for fair-lending officer - Hypothesis scorecard against manufactured-housing dealer overlay notes: supported / rejected / untestable - Examination and Notices finding in manufactured-housing dealer overlay notes that a second reviewer can re-perform - Missing page in manufactured-housing dealer overlay notes after a DOJ or CFPB monitor request for pricing files, if any