Assess whether pricing disparities are justified by legitimate factors

SITUATION A bank with thin HMDA LAR quality cannot treat a notice that cites 'other' as the principal reason 40% of the time as incidental context on SPCP written plan versus actual originations. Fair-lending officer must close pricing disparities are justified from that extract under Fair Lending / CRA and Special-Purpose Programs.

DECISION Fair-lending officer in a bank with thin HMDA LAR quality 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 notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. A notice that cites 'other' as the principal reason 40% of the time is noise around an already-controlled CRA and Special-Purpose Programs process in a bank with thin HMDA LAR quality, given SPCP written plan versus actual originations. 2. A notice that cites 'other' as the principal reason 40% of the time is the event in SPCP written plan versus actual originations that forces Remove access or reverse the item for fair-lending officer under Fair Lending. 3. SPCP written plan versus actual originations shows a one-file miss after a notice that cites 'other' as the principal reason 40% of the time, not a CRA and Special-Purpose Programs program failure. 4. SPCP written plan versus actual originations cannot decide pricing disparities are justified yet after a notice that cites 'other' as the principal reason 40% of the time; hold is the only Fair Lending close a bank with thin HMDA LAR quality can defend.

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 notice that cites 'other' as the principal reason 40% of the time. 4. For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations against a notice that cites 'other' as the principal reason 40% of the time 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 / CRA and Special-Purpose Programs packet (SPCP written plan versus actual originations after a notice that cites 'other' as the principal reason 40% of the time). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a notice that cites 'other' as the principal reason 40% of the time, then the two facts that force it, then the Monday action for fair-lending officer in a bank with thin HMDA LAR quality.