Assess whether pricing disparities are justified by legitimate factors

SITUATION Fair-lending officer is responsible for pricing disparities are justified in a manufactured-housing lender, using dealer-originated files with SPCP written plan versus actual originations as the only working extract. A vendor score change with no disparate-impact test is what reset the timeline for this Fair Lending Redlining and HMDA Data file.

DECISION Fair-lending officer in a manufactured-housing lender with dealer-originated files must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using SPCP written plan versus actual originations after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; SPCP written plan versus actual originations already has the discriminator after a vendor score change with no disparate-impact test. 2. Keep Temporary compensating control in force until SPCP written plan versus actual originations is completed after a vendor score change with no disparate-impact test for fair-lending officer. 3. Treat SPCP written plan versus actual originations 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: fair-lending officer does not have the decision pricing disparities are justified turns on in SPCP written plan versus actual originations.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in SPCP written plan versus actual originations. 2. Check HMDA coding and underwriting policy against pricing disparities are justified. 3. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test. 4. For this Fair Lending Redlining and HMDA Data file, read SPCP written plan versus actual originations against a vendor score change with no disparate-impact test and write the one fact that would move pricing disparities are justified for fair-lending officer.

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 (SPCP written plan versus actual originations after a vendor score change with no disparate-impact test). The follow-on Redlining and HMDA Data action is what fair-lending officer does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on pricing disparities are justified, then the evidence in SPCP written plan versus actual originations, then the action for fair-lending officer - Hypothesis scorecard against SPCP written plan versus actual originations: supported / rejected / untestable - Named option among Remove access or reverse the item, Temporary compensating control, Approve a documented exception and the fact that kills the others - Owner and next date for fair-lending officer in a manufactured-housing lender with dealer-originated files