Assess whether pricing disparities are justified by legitimate factors

SITUATION In a lender expanding into majority-minority census tracts, manufactured-housing dealer overlay notes is the evidence after a vendor score change with no disparate-impact test. Model-risk partner for credit scoring has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Examination and Notices close using manufactured-housing dealer overlay notes.

DECISION Model-risk partner for credit scoring in a lender expanding into majority-minority census tracts must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using manufactured-housing dealer overlay notes after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; manufactured-housing dealer overlay notes already has the discriminator after a vendor score change with no disparate-impact test. 2. Keep Temporary compensating control in force until manufactured-housing dealer overlay notes is completed after a vendor score change with no disparate-impact test for model-risk partner for credit scoring. 3. Treat manufactured-housing dealer overlay notes as Approve a documented exception because both readings appear after a vendor score change with no disparate-impact test. 4. Refuse a Fair Lending close: model-risk partner for credit scoring does not have the decision pricing disparities are justified turns on in manufactured-housing dealer overlay notes.

ANALYSIS REQUIRED 1. Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test. 2. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from manufactured-housing dealer overlay notes. 3. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 4. For this Fair Lending Examination and Notices file, read manufactured-housing dealer overlay notes against a vendor score change with no disparate-impact test and write the one fact that would move pricing disparities are justified for model-risk partner for credit scoring.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (manufactured-housing dealer overlay notes after a vendor score change with no disparate-impact test). If manufactured-housing dealer overlay notes cannot force a Fair Lending label under Examination and Notices, stop. Do not invent missing evidence a lender expanding into majority-minority census tracts does not have.