Assess whether pricing disparities are justified by legitimate factors

SITUATION A marketing mailer that skipped majority-minority tracts put SPCP written plan versus actual originations in front of exam-response coordinator in a manufactured-housing lender with dealer-originated files. This Fair Lending / CRA and Special-Purpose Programs close is pricing disparities are justified from SPCP written plan versus actual originations, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

DECISION Exam-response coordinator 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 marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. The population in SPCP written plan versus actual originations is the one a marketing mailer that skipped majority-minority tracts named, so Remove access or reverse the item follows for this CRA and Special-Purpose Programs file. 2. The population in SPCP written plan versus actual originations is adjacent only to a marketing mailer that skipped majority-minority tracts; Temporary compensating control is the honest Fair Lending call. 3. A manufactured-housing lender with dealer-originated files already contained a marketing mailer that skipped majority-minority tracts before SPCP written plan versus actual originations arrived; no new CRA and Special-Purpose Programs path. 4. Provenance on SPCP written plan versus actual originations after a marketing mailer that skipped majority-minority tracts is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Flag any disparate-impact table exam-response coordinator cannot explain from SPCP written plan versus actual originations. 2. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 3. Match the adverse-action language to the facts in SPCP written plan versus actual originations. 4. For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations against a marketing mailer that skipped majority-minority tracts 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 / CRA and Special-Purpose Programs packet (SPCP written plan versus actual originations after a marketing mailer that skipped majority-minority tracts). If SPCP written plan versus actual originations cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If SPCP written plan versus actual originations after a marketing mailer that skipped majority-minority tracts cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending CRA and Special-Purpose Programs close, exam-response coordinator must do not infer a control or scheme beyond the transaction and entitlement evidence.