Assess whether pricing disparities are justified by legitimate factors

SITUATION Geographic application and origination heat map arrived with a community complaint about appraisal gaps for fair-lending officer. That is a Fair Lending Redlining and HMDA Data decision on pricing disparities are justified in a manufactured-housing lender with dealer-originated files.

DECISION Fair-lending officer 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 geographic application and origination heat map after a community complaint about appraisal gaps.

HYPOTHESES TO TEST 1. Fair-lending officer can defend Remove access or reverse the item from geographic application and origination heat map 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 geographic application and origination heat map; 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 geographic application and origination heat map — reopen intake, do not close pricing disparities are justified. 4. Two facts in geographic application and origination heat map after a community complaint about appraisal gaps conflict for fair-lending officer; hold this Redlining and HMDA Data file.

ANALYSIS REQUIRED 1. Compare geographic application and origination heat map 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 geographic application and origination heat map. 3. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 4. For this Fair Lending Redlining and HMDA Data file, read geographic application and origination heat map 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 / Redlining and HMDA Data packet (geographic application and origination heat map after a community complaint about appraisal gaps). The follow-on Redlining and HMDA Data action is what fair-lending officer 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 geographic application and origination heat map, then the action for fair-lending officer - Hypothesis scorecard against geographic application and origination heat map: supported / rejected / untestable - Missing page in geographic application and origination heat map after a community complaint about appraisal gaps, if any - Regulatory or exam hook Redlining and HMDA Data would cite