Community-development lender must resolve whether pricing disparities are

Situation

Community-development lender in a bank with thin HMDA LAR quality has one working extract — geographic application and origination heat map — after a board asking if the bank should settle a matched-pair study. If geographic application and origination heat map cannot support pricing disparities are justified, the honest Fair Lending output is hold.

Decision

Community-development lender 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 geographic application and origination heat map after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• Geographic application and origination heat map reads as Remove access or reverse the item once a board asking if the bank should settle a matched-pair study is lined up to the same Fair Lending population.
• Geographic application and origination heat map is closer to Temporary compensating control after a board asking if the bank should settle a matched-pair study; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract.
• Approve a documented exception is still live in geographic application and origination heat map for community-development lender in a bank with thin HMDA LAR quality.
• Geographic application and origination heat map is missing the fact community-development lender needs after a board asking if the bank should settle a matched-pair study; stop this Fair Lending close.

Analysis required

• Flag any disparate-impact table community-development lender cannot explain from geographic application and origination heat map.
• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• Match the adverse-action language to the facts in geographic application and origination heat map.
• For this Fair Lending Pricing and Credit Limits file, read geographic application and origination heat map 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 community-development lender.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (geographic application and origination heat map after a board asking if the bank should settle a matched-pair study). If geographic application and origination heat map cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent pages a bank with thin HMDA LAR quality does not have.