Assess whether pricing disparities are justified by legitimate factors

SITUATION In a bank with thin HMDA LAR quality, CRA assessment-area versus lending footprint is the evidence after a branch that stopped taking applications in one ZIP. Fair-lending officer has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs close using CRA assessment-area versus lending footprint.

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 CRA assessment-area versus lending footprint after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; CRA assessment-area versus lending footprint already has the discriminator after a branch that stopped taking applications in one ZIP. 2. Keep Temporary compensating control in force until CRA assessment-area versus lending footprint is completed after a branch that stopped taking applications in one ZIP for fair-lending officer. 3. Treat CRA assessment-area versus lending footprint as Approve a documented exception because both readings appear after a branch that stopped taking applications in one ZIP. 4. Refuse a Fair Lending close: fair-lending officer does not have the decision pricing disparities are justified turns on in CRA assessment-area versus lending footprint.

ANALYSIS REQUIRED 1. Flag any disparate-impact table fair-lending officer cannot explain from CRA assessment-area versus lending footprint. 2. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 3. Match the adverse-action language to the facts in CRA assessment-area versus lending footprint. 4. For this Fair Lending CRA and Special-Purpose Programs file, read CRA assessment-area versus lending footprint against a branch that stopped taking applications in one ZIP 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 (CRA assessment-area versus lending footprint after a branch that stopped taking applications in one ZIP). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after a branch that stopped taking applications in one ZIP, then the two facts that force it, then the Monday action for fair-lending officer in a bank with thin HMDA LAR quality.

COMMAND RETURNS - Bottom-line Fair Lending option on pricing disparities are justified, then the evidence in CRA assessment-area versus lending footprint, then the action for fair-lending officer - Hypothesis scorecard against CRA assessment-area versus lending footprint: supported / rejected / untestable - Named option among Remove access or reverse the item, Temporary compensating control, Approve a documented exception and the fact that kills the others - Owner and next date for fair-lending officer in a bank with thin HMDA LAR quality