Assess whether pricing disparities are justified by legitimate factors

SITUATION HMDA data-quality manager is responsible for pricing disparities are justified in a credit-card issuer changing line-assignment logic, using SPCP written plan versus actual originations as the only working extract. An exception rate twice as high for one group after credit controls is what reset the timeline for this Fair Lending Redlining and HMDA Data file.

DECISION HMDA data-quality manager in a credit-card issuer changing line-assignment logic must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using SPCP written plan versus actual originations after an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; SPCP written plan versus actual originations already has the discriminator after an exception rate twice as high for one group after credit controls. 2. Keep Temporary compensating control in force until SPCP written plan versus actual originations is completed after an exception rate twice as high for one group after credit controls for HMDA data-quality manager. 3. Treat SPCP written plan versus actual originations as Approve a documented exception because both readings appear after an exception rate twice as high for one group after credit controls. 4. Refuse a Fair Lending close: HMDA data-quality manager does not have the decision pricing disparities are justified turns on in SPCP written plan versus actual originations.

ANALYSIS REQUIRED 1. Flag any disparate-impact table HMDA data-quality manager cannot explain from SPCP written plan versus actual originations. 2. Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend. 3. Match the adverse-action language to the facts in SPCP written plan versus actual originations. 4. For this Fair Lending Redlining and HMDA Data file, read SPCP written plan versus actual originations against an exception rate twice as high for one group after credit controls and write the one fact that would move pricing disparities are justified for HMDA data-quality manager.

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 an exception rate twice as high for one group after credit controls). The follow-on Redlining and HMDA Data action is what HMDA data-quality manager 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 HMDA data-quality manager - Hypothesis scorecard against SPCP written plan versus actual originations: supported / rejected / untestable - Missing page in SPCP written plan versus actual originations after an exception rate twice as high for one group after credit controls, if any - Regulatory or exam hook Redlining and HMDA Data would cite