Assess whether pricing disparities are justified by legitimate factors

SITUATION CRA strategist is responsible for pricing disparities are justified in a mortgage company after a pricing-regression spike, using CRA assessment-area versus lending footprint as the only working extract. A SPCP that originated almost no loans to the intended class is what reset the timeline for this Fair Lending CRA and Special-Purpose Programs file.

DECISION CRA strategist in a mortgage company after a pricing-regression spike 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 SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. CRA strategist can defend Remove access or reverse the item from CRA assessment-area versus lending footprint after a SPCP that originated almost no loans to the intended class in a Fair Lending challenge. 2. CRA strategist cannot defend Remove access or reverse the item from CRA assessment-area versus lending footprint; Temporary compensating control is what the extract actually supports after a SPCP that originated almost no loans to the intended class. 3. A SPCP that originated almost no loans to the intended class never reached the population in CRA assessment-area versus lending footprint — reopen intake, do not close pricing disparities are justified. 4. Two facts in CRA assessment-area versus lending footprint after a SPCP that originated almost no loans to the intended class conflict for CRA strategist; hold this CRA and Special-Purpose Programs file.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend. 2. Match the adverse-action language to the facts in CRA assessment-area versus lending footprint. 3. Check HMDA coding and underwriting policy against pricing disparities are justified. 4. For this Fair Lending CRA and Special-Purpose Programs file, read CRA assessment-area versus lending footprint against a SPCP that originated almost no loans to the intended class and write the one fact that would move pricing disparities are justified for CRA strategist.

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 SPCP that originated almost no loans to the intended class). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after a SPCP that originated almost no loans to the intended class, then the two facts that force it, then the Monday action for CRA strategist in a mortgage company after a pricing-regression spike.