Assess whether pricing disparities are justified by legitimate factors

SITUATION Geographic application and origination heat map arrived with a HMDA resubmission that still fails quality edits for CRA strategist. That is a Fair Lending Redlining and HMDA Data decision on pricing disparities are justified in an institution preparing for a redlining exam.

DECISION CRA strategist in an institution preparing for a redlining exam 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 HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. Geographic application and origination heat map reads as Remove access or reverse the item once a HMDA resubmission that still fails quality edits is lined up to the same Fair Lending population. 2. Geographic application and origination heat map is closer to Temporary compensating control after a HMDA resubmission that still fails quality edits; Remove access or reverse the item would over-claim this Redlining and HMDA Data extract. 3. Approve a documented exception is still live in geographic application and origination heat map for CRA strategist in an institution preparing for a redlining exam. 4. Geographic application and origination heat map is missing the fact CRA strategist needs after a HMDA resubmission that still fails quality edits; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against pricing disparities are justified. 2. Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits. 3. Flag any disparate-impact table CRA strategist cannot explain from geographic application and origination heat map. 4. For this Fair Lending Redlining and HMDA Data file, read geographic application and origination heat map against a HMDA resubmission that still fails quality edits 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 / Redlining and HMDA Data packet (geographic application and origination heat map after a HMDA resubmission that still fails quality edits). If geographic application and origination heat map cannot force a Fair Lending label under Redlining and HMDA Data, stop. If geographic application and origination heat map after a HMDA resubmission that still fails quality edits cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Redlining and HMDA Data close, CRA strategist must do not infer a control or scheme beyond the transaction and entitlement evidence.