Fair-lending officer must resolve whether pricing disparities are justified

Situation

The desk packet is appraisal-gap outcomes in majority-minority tracts after a SPCP that originated almost no loans to the intended class. Fair-lending officer in a mortgage company after a pricing-regression spike has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits file.

Decision

Fair-lending officer 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 appraisal-gap outcomes in majority-minority tracts after a SPCP that originated almost no loans to the intended class.

Hypotheses to test

• Authorize Remove access or reverse the item now; appraisal-gap outcomes in majority-minority tracts already has the discriminator after a SPCP that originated almost no loans to the intended class.
• Keep Temporary compensating control in force until appraisal-gap outcomes in majority-minority tracts is completed after a SPCP that originated almost no loans to the intended class for fair-lending officer.
• Treat appraisal-gap outcomes in majority-minority tracts as Approve a documented exception because both readings appear after a SPCP that originated almost no loans to the intended class.
• Refuse a Fair Lending close: fair-lending officer does not have the page pricing disparities are justified turns on in appraisal-gap outcomes in majority-minority tracts.

Analysis required

• Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts.
• Check HMDA coding and underwriting policy against pricing disparities are justified.
• Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class.
• For this Fair Lending Pricing and Credit Limits file, read appraisal-gap outcomes in majority-minority tracts 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 fair-lending officer.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (appraisal-gap outcomes in majority-minority tracts after a SPCP that originated almost no loans to the intended class). If appraisal-gap outcomes in majority-minority tracts cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent pages a mortgage company after a pricing-regression spike does not have.