Assess whether pricing disparities are justified by legitimate factors

SITUATION An underwriter chat that used coded language put small-business decline comparative file set in front of CRA strategist in a mortgage company after a pricing-regression spike. This Fair Lending / CRA and Special-Purpose Programs close is pricing disparities are justified from small-business decline comparative file set, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

DECISION CRA strategist in a mortgage company after a pricing-regression spike must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using small-business decline comparative file set after an underwriter chat that used coded language.

HYPOTHESES TO TEST 1. An underwriter chat that used coded language is noise around an already-controlled CRA and Special-Purpose Programs process in a mortgage company after a pricing-regression spike, given small-business decline comparative file set. 2. An underwriter chat that used coded language is the event in small-business decline comparative file set that forces Remove access or reverse the item for CRA strategist under Fair Lending. 3. Small-business decline comparative file set shows a one-file miss after an underwriter chat that used coded language, not a CRA and Special-Purpose Programs program failure. 4. Small-business decline comparative file set cannot decide pricing disparities are justified yet after an underwriter chat that used coded language; hold is the only Fair Lending close a mortgage company after a pricing-regression spike can defend.

ANALYSIS REQUIRED 1. Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language. 2. Flag any disparate-impact table CRA strategist cannot explain from small-business decline comparative file set. 3. Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend. 4. For this Fair Lending CRA and Special-Purpose Programs file, read small-business decline comparative file set against an underwriter chat that used coded language and write the one fact that would move pricing disparities are justified for CRA strategist.

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 (small-business decline comparative file set after an underwriter chat that used coded language). The follow-on CRA and Special-Purpose Programs action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.