Assess whether pricing disparities are justified by legitimate factors

SITUATION A SPCP that originated almost no loans to the intended class put model-reason-code mapping that does not match notices in front of CRA strategist in a bank with thin HMDA LAR quality. This Fair Lending / Examination and Notices close is pricing disparities are justified from model-reason-code mapping that does not match notices, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

DECISION CRA strategist 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 model-reason-code mapping that does not match notices after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. The population in model-reason-code mapping that does not match notices is the one a SPCP that originated almost no loans to the intended class named, so Remove access or reverse the item follows for this Examination and Notices file. 2. The population in model-reason-code mapping that does not match notices is adjacent only to a SPCP that originated almost no loans to the intended class; Temporary compensating control is the honest Fair Lending call. 3. A bank with thin HMDA LAR quality already contained a SPCP that originated almost no loans to the intended class before model-reason-code mapping that does not match notices arrived; no new Examination and Notices path. 4. Provenance on model-reason-code mapping that does not match notices after a SPCP that originated almost no loans to the intended class is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class. 2. Flag any disparate-impact table CRA strategist cannot explain from model-reason-code mapping that does not match notices. 3. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 4. For this Fair Lending Examination and Notices file, read model-reason-code mapping that does not match notices 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 / Examination and Notices packet (model-reason-code mapping that does not match notices after a SPCP that originated almost no loans to the intended class). The follow-on Examination and Notices action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.