Assess whether pricing disparities are justified by legitimate factors

SITUATION After a CRA PE that called the assessment area too narrow, appraisal-gap outcomes in majority-minority tracts is what model-risk partner for credit scoring can touch in a credit union rolling out a special-purpose credit program. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Redlining and HMDA Data file.

DECISION Model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program 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 CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. The population in appraisal-gap outcomes in majority-minority tracts is the one a CRA PE that called the assessment area too narrow named, so Remove access or reverse the item follows for this Redlining and HMDA Data file. 2. The population in appraisal-gap outcomes in majority-minority tracts is adjacent only to a CRA PE that called the assessment area too narrow; Temporary compensating control is the honest Fair Lending call. 3. A credit union rolling out a special-purpose credit program already contained a CRA PE that called the assessment area too narrow before appraisal-gap outcomes in majority-minority tracts arrived; no new Redlining and HMDA Data path. 4. Provenance on appraisal-gap outcomes in majority-minority tracts after a CRA PE that called the assessment area too narrow is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against pricing disparities are justified. 2. Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow. 3. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from appraisal-gap outcomes in majority-minority tracts. 4. For this Fair Lending Redlining and HMDA Data file, read appraisal-gap outcomes in majority-minority tracts against a CRA PE that called the assessment area too narrow 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 / Redlining and HMDA Data packet (appraisal-gap outcomes in majority-minority tracts after a CRA PE that called the assessment area too narrow). Lead with the Fair Lending option appraisal-gap outcomes in majority-minority tracts can support after a CRA PE that called the assessment area too narrow, then the two facts that force it, then the Monday action for model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program.