Assess whether pricing disparities are justified by legitimate factors

SITUATION In a mortgage company after a pricing-regression spike, small-business decline comparative file set is the evidence after a branch that stopped taking applications in one ZIP. CRA strategist has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs close using small-business decline comparative file set.

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 small-business decline comparative file set after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. A branch that stopped taking applications in one ZIP is noise around an already-controlled CRA and Special-Purpose Programs process in a mortgage company after a pricing-regression spike, given small-business decline comparative file set. 2. A branch that stopped taking applications in one ZIP is the event in small-business decline comparative file set that forces Remove access or reverse the item for CRA strategist under Fair Lending. 3. Small-business decline comparative file set shows a one-file miss after a branch that stopped taking applications in one ZIP, not a CRA and Special-Purpose Programs program failure. 4. Small-business decline comparative file set cannot decide pricing disparities are justified yet after a branch that stopped taking applications in one ZIP; hold is the only Fair Lending close a mortgage company after a pricing-regression spike can defend.

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 small-business decline comparative file set. 3. Check HMDA coding and underwriting policy against pricing disparities are justified. 4. For this Fair Lending CRA and Special-Purpose Programs file, read small-business decline comparative file set against a branch that stopped taking applications in one ZIP 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 (small-business decline comparative file set after a branch that stopped taking applications in one ZIP). The follow-on CRA and Special-Purpose Programs action is what CRA strategist 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 small-business decline comparative file set, then the action for CRA strategist - Hypothesis scorecard against small-business decline comparative file set: supported / rejected / untestable - CRA and Special-Purpose Programs finding in small-business decline comparative file set that a second reviewer can re-perform - Missing page in small-business decline comparative file set after a branch that stopped taking applications in one ZIP, if any