Assess whether pricing disparities are justified by legitimate factors

SITUATION A vendor score change with no disparate-impact test raised whether pricing disparities are justified by legitimate factors for second-review underwriter at a small-business desk using a new vendor score. Mortgage pricing residual by prohibited-basis group is incomplete relative to that question, so Hold remains live until the file is complete.

DECISION Second-review underwriter in a small-business desk using a new vendor score 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 vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. A vendor score change with no disparate-impact test is noise around an already-controlled Redlining and HMDA Data process in a small-business desk using a new vendor score, given mortgage pricing residual by prohibited-basis group. 2. A vendor score change with no disparate-impact test is the event in mortgage pricing residual by prohibited-basis group that forces Remove access or reverse the item for second-review underwriter under Fair Lending. 3. Mortgage pricing residual by prohibited-basis group shows a one-file miss after a vendor score change with no disparate-impact test, not a Redlining and HMDA Data program failure. 4. Mortgage pricing residual by prohibited-basis group cannot decide pricing disparities are justified yet after a vendor score change with no disparate-impact test; hold is the only Fair Lending close a small-business desk using a new vendor score can defend.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a small-business desk using a new vendor score must defend. 2. Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group. 3. Check HMDA coding and underwriting policy against pricing disparities are justified. 4. For this Fair Lending Redlining and HMDA Data file, read mortgage pricing residual by prohibited-basis group against a vendor score change with no disparate-impact test and write the one fact that would move pricing disparities are justified for second-review underwriter.

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 vendor score change with no disparate-impact test). Lead with the Fair Lending option mortgage pricing residual by prohibited-basis group can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for second-review underwriter in a small-business desk using a new vendor score.