Assess whether pricing disparities are justified by legitimate factors

SITUATION CRA and Special-Purpose Programs work in a manufactured-housing lender with dealer-originated files now turns on pricing disparities are justified because a CRA PE that called the assessment area too narrow put mortgage pricing residual by prohibited-basis group in play. Exam-response coordinator should say what mortgage pricing residual by prohibited-basis group proves.

DECISION Exam-response coordinator in a manufactured-housing lender with dealer-originated files must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using mortgage pricing residual by prohibited-basis group after a CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. A CRA PE that called the assessment area too narrow is noise around an already-controlled CRA and Special-Purpose Programs process in a manufactured-housing lender with dealer-originated files, given mortgage pricing residual by prohibited-basis group. 2. A CRA PE that called the assessment area too narrow is the event in mortgage pricing residual by prohibited-basis group that forces Remove access or reverse the item for exam-response coordinator under Fair Lending. 3. Mortgage pricing residual by prohibited-basis group shows a one-file miss after a CRA PE that called the assessment area too narrow, not a CRA and Special-Purpose Programs program failure. 4. Mortgage pricing residual by prohibited-basis group cannot decide pricing disparities are justified yet after a CRA PE that called the assessment area too narrow; hold is the only Fair Lending close a manufactured-housing lender with dealer-originated files can defend.

ANALYSIS REQUIRED 1. Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow. 2. Flag any disparate-impact table exam-response coordinator cannot explain from mortgage pricing residual by prohibited-basis group. 3. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 4. For this Fair Lending CRA and Special-Purpose Programs file, read mortgage pricing residual by prohibited-basis group against a CRA PE that called the assessment area too narrow and write the one fact that would move pricing disparities are justified for exam-response coordinator.

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 (mortgage pricing residual by prohibited-basis group after a CRA PE that called the assessment area too narrow). The follow-on CRA and Special-Purpose Programs action is what exam-response coordinator does next: implement the option, assign an owner, and log the missing fact.