Assess whether pricing disparities are justified by legitimate factors

SITUATION A HMDA resubmission that still fails quality edits put manufactured-housing dealer overlay notes in front of model-risk partner for credit scoring in a lender expanding into majority-minority census tracts. This Fair Lending / Examination and Notices close is pricing disparities are justified from manufactured-housing dealer overlay notes, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

DECISION Model-risk partner for credit scoring 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 manufactured-housing dealer overlay notes after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; manufactured-housing dealer overlay notes already has the discriminator after a HMDA resubmission that still fails quality edits. 2. Keep Temporary compensating control in force until manufactured-housing dealer overlay notes is completed after a HMDA resubmission that still fails quality edits for model-risk partner for credit scoring. 3. Treat manufactured-housing dealer overlay notes as Approve a documented exception because both readings appear after a HMDA resubmission that still fails quality edits. 4. Refuse a Fair Lending close: model-risk partner for credit scoring does not have the decision pricing disparities are justified turns on in manufactured-housing dealer overlay notes.

ANALYSIS REQUIRED 1. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from manufactured-housing dealer overlay notes. 2. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 3. Match the adverse-action language to the facts in manufactured-housing dealer overlay notes. 4. For this Fair Lending Examination and Notices file, read manufactured-housing dealer overlay notes against a HMDA resubmission that still fails quality edits and write the one fact that would move pricing disparities are justified for model-risk partner for credit scoring.

RECOMMENDATION Remove access or reverse the item is the Fair Lending Examination and Notices move when manufactured-housing dealer overlay notes lines up with a HMDA resubmission that still fails quality edits for model-risk partner for credit scoring in a lender expanding into majority-minority census tracts. Temporary compensating control is the move when that alignment in manufactured-housing dealer overlay notes fails. Record the missing fact in manufactured-housing dealer overlay notes before anyone treats pricing disparities are justified as closed.