Assess whether pricing disparities are justified by legitimate factors

SITUATION Geographic application and origination heat map arrived with a branch that stopped taking applications in one ZIP for second-review underwriter. That is a Fair Lending Redlining and HMDA Data decision on pricing disparities are justified in a small-business desk using a new vendor score.

DECISION Second-review underwriter in a small-business desk using a new vendor score 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 branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. Authorize Remove access or reverse the item now; geographic application and origination heat map already has the discriminator after a branch that stopped taking applications in one ZIP. 2. Keep Temporary compensating control in force until geographic application and origination heat map is completed after a branch that stopped taking applications in one ZIP for second-review underwriter. 3. Treat geographic application and origination heat map as Approve a documented exception because both readings appear after a branch that stopped taking applications in one ZIP. 4. Refuse a Fair Lending close: second-review underwriter does not have the decision pricing disparities are justified turns on in geographic application and origination heat map.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a small-business desk using a new vendor score must defend. 2. Match the adverse-action language to the facts in geographic application and origination heat map. 3. Check HMDA coding and underwriting policy against pricing disparities are justified. 4. For this Fair Lending Redlining and HMDA Data file, read geographic application and origination heat map against a branch that stopped taking applications in one ZIP and write the one fact that would move pricing disparities are justified for second-review underwriter.

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 branch that stopped taking applications in one ZIP). Lead with the Fair Lending option geographic application and origination heat map can support after a branch that stopped taking applications in one ZIP, then the two facts that force it, then the Monday action for second-review underwriter in a small-business desk using a new vendor score.

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 second-review underwriter - Hypothesis scorecard against geographic application and origination heat map: supported / rejected / untestable - Missing page in geographic application and origination heat map after a branch that stopped taking applications in one ZIP, if any - Regulatory or exam hook Redlining and HMDA Data would cite