Assess whether pricing disparities are justified by legitimate factors

SITUATION The working file is credit-card limit assignment disparity table after a community complaint about appraisal gaps. Fair-lending officer in a bank with thin HMDA LAR quality has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending CRA and Special-Purpose Programs file.

DECISION Fair-lending officer 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 credit-card limit assignment disparity table after a community complaint about appraisal gaps.

HYPOTHESES TO TEST 1. Fair-lending officer can defend Remove access or reverse the item from credit-card limit assignment disparity table after a community complaint about appraisal gaps in a Fair Lending challenge. 2. Fair-lending officer cannot defend Remove access or reverse the item from credit-card limit assignment disparity table; Temporary compensating control is what the extract actually supports after a community complaint about appraisal gaps. 3. A community complaint about appraisal gaps never reached the population in credit-card limit assignment disparity table — reopen intake, do not close pricing disparities are justified. 4. Two facts in credit-card limit assignment disparity table after a community complaint about appraisal gaps conflict for fair-lending officer; hold this CRA and Special-Purpose Programs file.

ANALYSIS REQUIRED 1. Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps. 2. Flag any disparate-impact table fair-lending officer cannot explain from credit-card limit assignment disparity table. 3. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 4. For this Fair Lending CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table against a community complaint about appraisal gaps 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 / CRA and Special-Purpose Programs packet (credit-card limit assignment disparity table after a community complaint about appraisal gaps). Lead with the Fair Lending option credit-card limit assignment disparity table can support after a community complaint about appraisal gaps, then the two facts that force it, then the Monday action for fair-lending officer in a bank with thin HMDA LAR quality.

COMMAND RETURNS - Bottom-line Fair Lending option on pricing disparities are justified, then the evidence in credit-card limit assignment disparity table, then the action for fair-lending officer - Hypothesis scorecard against credit-card limit assignment disparity table: supported / rejected / untestable - What changes pricing disparities are justified if a community complaint about appraisal gaps is later withdrawn - Named option among Remove access or reverse the item, Temporary compensating control, Approve a documented exception and the fact that kills the others