Assess whether pricing disparities are justified by legitimate factors

SITUATION The working file is geographic application and origination heat map after a vendor score change with no disparate-impact test. Exam-response coordinator in an institution preparing for a redlining exam has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits file.

DECISION Exam-response coordinator 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 geographic application and origination heat map after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; geographic application and origination heat map already has the discriminator after a vendor score change with no disparate-impact test. 2. Keep Temporary compensating control in force until geographic application and origination heat map is completed after a vendor score change with no disparate-impact test for exam-response coordinator. 3. Treat geographic application and origination heat map as Approve a documented exception because both readings appear after a vendor score change with no disparate-impact test. 4. Refuse a Fair Lending close: exam-response coordinator does not have the decision pricing disparities are justified turns on in geographic application and origination heat map.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern an institution preparing for a redlining exam must defend. 2. Match the adverse-action language to the facts in geographic application and origination heat map. 3. Check HMDA coding and underwriting policy against pricing disparities are justified. 4. For this Fair Lending Pricing and Credit Limits file, read geographic application and origination heat map against a vendor score change with no disparate-impact test 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 / Pricing and Credit Limits packet (geographic application and origination heat map after a vendor score change with no disparate-impact test). Lead with the Fair Lending option geographic application and origination heat map can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for exam-response coordinator in an institution preparing for a redlining exam.

COMMAND RETURNS - Bottom-line Fair Lending option on pricing disparities are justified, then the evidence in geographic application and origination heat map, then the action for exam-response coordinator - Hypothesis scorecard against geographic application and origination heat map: supported / rejected / untestable - Regulatory or exam hook Pricing and Credit Limits would cite - Pricing and Credit Limits finding in geographic application and origination heat map that a second reviewer can re-perform