Assess whether pricing disparities are justified by legitimate factors

SITUATION Mortgage pricing residual by prohibited-basis group arrived with a branch that stopped taking applications in one ZIP for exam-response coordinator; this Fair Lending Redlining and HMDA Data close is pricing disparities are justified in a bank with thin HMDA LAR quality. That is a Fair Lending Redlining and HMDA Data decision on pricing disparities are justified in a bank with thin HMDA LAR quality.

DECISION Exam-response coordinator in a bank with thin HMDA LAR quality must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using mortgage pricing residual by prohibited-basis group after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; mortgage pricing residual by prohibited-basis group already has the discriminator after a branch that stopped taking applications in one ZIP. 2. Keep Temporary compensating control in force until mortgage pricing residual by prohibited-basis group is completed after a branch that stopped taking applications in one ZIP for exam-response coordinator. 3. Treat mortgage pricing residual by prohibited-basis group as Approve a documented exception because both readings appear after a branch that stopped taking applications in one ZIP. 4. Refuse a Fair Lending close: exam-response coordinator does not have the decision pricing disparities are justified turns on in mortgage pricing residual by prohibited-basis group.

ANALYSIS REQUIRED 1. Flag any disparate-impact table exam-response coordinator cannot explain from mortgage pricing residual by prohibited-basis group. 2. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 3. Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group. 4. For this Fair Lending Redlining and HMDA Data file, read mortgage pricing residual by prohibited-basis group against a branch that stopped taking applications in one ZIP and write the one fact that would move pricing disparities are justified for exam-response coordinator.

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 (mortgage pricing residual by prohibited-basis group after a branch that stopped taking applications in one ZIP). If mortgage pricing residual by prohibited-basis group cannot force a Fair Lending label under Redlining and HMDA Data, stop. If mortgage pricing residual by prohibited-basis group after a branch that stopped taking applications in one ZIP cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Redlining and HMDA Data close, exam-response coordinator must do not infer a control or scheme beyond the transaction and entitlement evidence.