Assess whether pricing disparities are justified by legitimate factors

SITUATION After a HMDA resubmission that still fails quality edits, HMDA LAR validity and quality edits is the working evidence for community-development lender in a manufactured-housing lender with dealer-originated files. Decide whether pricing disparities are justified by legitimate factors using only what HMDA LAR validity and quality edits actually supports.

DECISION Community-development lender 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 HMDA LAR validity and quality edits after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. The population in HMDA LAR validity and quality edits is the one a HMDA resubmission that still fails quality edits named, so Remove access or reverse the item follows for this Examination and Notices file. 2. The population in HMDA LAR validity and quality edits is adjacent only to a HMDA resubmission that still fails quality edits; Temporary compensating control is the honest Fair Lending call. 3. A manufactured-housing lender with dealer-originated files already contained a HMDA resubmission that still fails quality edits before HMDA LAR validity and quality edits arrived; no new Examination and Notices path. 4. Provenance on HMDA LAR validity and quality edits after a HMDA resubmission that still fails quality edits is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits. 2. Flag any disparate-impact table community-development lender cannot explain from HMDA LAR validity and quality edits. 3. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 4. For this Fair Lending Examination and Notices file, read HMDA LAR validity and quality edits against a HMDA resubmission that still fails quality edits 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 / Examination and Notices packet (HMDA LAR validity and quality edits after a HMDA resubmission that still fails quality edits). The follow-on Examination and Notices action is what community-development lender does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on pricing disparities are justified, then the evidence in HMDA LAR validity and quality edits, then the action for community-development lender - Hypothesis scorecard against HMDA LAR validity and quality edits: supported / rejected / untestable - Owner and next date for community-development lender in a manufactured-housing lender with dealer-originated files - What changes pricing disparities are justified if a HMDA resubmission that still fails quality edits is later withdrawn