Assess whether pricing disparities are justified by legitimate factors

SITUATION A mortgage company after a pricing-regression spike cannot treat a HMDA resubmission that still fails quality edits as incidental context on SPCP written plan versus actual originations. Community-development lender must close pricing disparities are justified from that extract under Fair Lending / Redlining and HMDA Data.

DECISION Community-development lender 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 SPCP written plan versus actual originations after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. A HMDA resubmission that still fails quality edits is noise around an already-controlled Redlining and HMDA Data process in a mortgage company after a pricing-regression spike, given SPCP written plan versus actual originations. 2. A HMDA resubmission that still fails quality edits is the event in SPCP written plan versus actual originations that forces Remove access or reverse the item for community-development lender under Fair Lending. 3. SPCP written plan versus actual originations shows a one-file miss after a HMDA resubmission that still fails quality edits, not a Redlining and HMDA Data program failure. 4. SPCP written plan versus actual originations cannot decide pricing disparities are justified yet after a HMDA resubmission that still fails quality edits; hold is the only Fair Lending close a mortgage company after a pricing-regression spike can defend.

ANALYSIS REQUIRED 1. Flag any disparate-impact table community-development lender cannot explain from SPCP written plan versus actual originations. 2. Test a documented exception versus a pattern a mortgage company after a pricing-regression spike 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 a HMDA resubmission that still fails quality edits and write the one fact that would move pricing disparities are justified for community-development lender.

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 HMDA resubmission that still fails quality edits). The follow-on Redlining and HMDA Data action is what community-development lender 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 community-development lender - Hypothesis scorecard against SPCP written plan versus actual originations: supported / rejected / untestable - Redlining and HMDA Data finding in SPCP written plan versus actual originations that a second reviewer can re-perform - Missing page in SPCP written plan versus actual originations after a HMDA resubmission that still fails quality edits, if any