Assess whether pricing disparities are justified by legitimate factors

SITUATION CRA and Special-Purpose Programs work in an institution preparing for a redlining exam now turns on pricing disparities are justified because a HMDA resubmission that still fails quality edits put model-reason-code mapping that does not match notices in play. CRA and Special-Purpose Programs work in an institution preparing for a redlining exam now turns on pricing disparities are justified because a HMDA resubmission that still fails quality edits put model-reason-code mapping that does not match notices in play; community-development lender should say what model-reason-code mapping that does not match notices proves for Fair Lending.

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 model-reason-code mapping that does not match notices after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. Community-development lender can defend Remove access or reverse the item from model-reason-code mapping that does not match notices after a HMDA resubmission that still fails quality edits in a Fair Lending challenge. 2. Community-development lender cannot defend Remove access or reverse the item from model-reason-code mapping that does not match notices; Temporary compensating control is what the extract actually supports after a HMDA resubmission that still fails quality edits. 3. A HMDA resubmission that still fails quality edits never reached the population in model-reason-code mapping that does not match notices — reopen intake, do not close pricing disparities are justified. 4. Two facts in model-reason-code mapping that does not match notices after a HMDA resubmission that still fails quality edits conflict for community-development lender; hold this CRA and Special-Purpose Programs file.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against pricing disparities are justified. 2. Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits. 3. Flag any disparate-impact table community-development lender cannot explain from model-reason-code mapping that does not match notices. 4. For this Fair Lending CRA and Special-Purpose Programs file, read model-reason-code mapping that does not match notices against a HMDA resubmission that still fails quality edits 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 (model-reason-code mapping that does not match notices after a HMDA resubmission that still fails quality edits). The follow-on CRA and Special-Purpose Programs action is what community-development lender does next: implement the option, assign an owner, and log the missing fact.