Assess whether pricing disparities are justified by legitimate factors

SITUATION A SPCP that originated almost no loans to the intended class put underwriting exception log by branch in front of exam-response coordinator in a mortgage company after a pricing-regression spike. This Fair Lending / Examination and Notices close is pricing disparities are justified from underwriting exception log by branch, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

DECISION Exam-response coordinator 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 underwriting exception log by branch after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. The population in underwriting exception log by branch 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 underwriting exception log by branch 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 mortgage company after a pricing-regression spike already contained a SPCP that originated almost no loans to the intended class before underwriting exception log by branch arrived; no new Examination and Notices path. 4. Provenance on underwriting exception log by branch 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 underwriting exception log by branch 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 exam-response coordinator cannot explain from underwriting exception log by branch. 3. Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend. 4. For this Fair Lending Examination and Notices file, read underwriting exception log by branch 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 exam-response coordinator.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (underwriting exception log by branch after a SPCP that originated almost no loans to the intended class). The follow-on Examination and Notices action is what exam-response coordinator does next: implement the option, assign an owner, and log the missing fact.