Assess whether pricing disparities are justified by legitimate factors

SITUATION A bank with thin HMDA LAR quality cannot treat a board asking if the bank should settle a matched-pair study as incidental context on small-business decline comparative file set. 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 small-business decline comparative file set 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; small-business decline comparative file set 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 small-business decline comparative file set is completed after a board asking if the bank should settle a matched-pair study for fair-lending officer. 3. Treat small-business decline comparative file set 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: fair-lending officer does not have the decision pricing disparities are justified turns on in small-business decline comparative file set.

ANALYSIS REQUIRED 1. Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study. 2. Flag any disparate-impact table fair-lending officer cannot explain from small-business decline comparative file set. 3. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 4. For this Fair Lending CRA and Special-Purpose Programs file, read small-business decline comparative file set 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 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 (small-business decline comparative file set after a board asking if the bank should settle a matched-pair study). Lead with the Fair Lending option small-business decline comparative file set can support after a board asking if the bank should settle a matched-pair study, then the two facts that force it, then the Monday action for fair-lending officer in a bank with thin HMDA LAR quality.