Assess whether pricing disparities are justified by legitimate factors

SITUATION After a board asking if the bank should settle a matched-pair study, SPCP written plan versus actual originations is the working evidence for model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program. Decide whether pricing disparities are justified by legitimate factors using only what SPCP written plan versus actual originations actually supports.

DECISION Model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program 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 board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; SPCP written plan versus actual originations already has the discriminator after a board asking if the bank should settle a matched-pair study. 2. Keep Temporary compensating control in force until SPCP written plan versus actual originations is completed after a board asking if the bank should settle a matched-pair study for model-risk partner for credit scoring. 3. Treat SPCP written plan versus actual originations as Approve a documented exception because both readings appear after a board asking if the bank should settle a matched-pair study. 4. Refuse a Fair Lending close: model-risk partner for credit scoring does not have the decision pricing disparities are justified turns on in SPCP written plan versus actual originations.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 2. Match the adverse-action language to the facts in SPCP written plan versus actual originations. 3. Check HMDA coding and underwriting policy against pricing disparities are justified. 4. For this Fair Lending Redlining and HMDA Data file, read SPCP written plan versus actual originations against a board asking if the bank should settle a matched-pair study and write the one fact that would move pricing disparities are justified for model-risk partner for credit scoring.

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 board asking if the bank should settle a matched-pair study). If SPCP written plan versus actual originations cannot force a Fair Lending label under Redlining and HMDA Data, stop. If SPCP written plan versus actual originations after a board asking if the bank should settle a matched-pair study cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Redlining and HMDA Data close, model-risk partner for credit scoring must do not infer a control or scheme beyond the transaction and entitlement evidence.