Assess whether pricing disparities are justified by legitimate factors

SITUATION After a HMDA resubmission that still fails quality edits, small-business decline comparative file set is what second-review underwriter 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 Examination and Notices file.

DECISION Second-review underwriter 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 small-business decline comparative file set after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. A HMDA resubmission that still fails quality edits is noise around an already-controlled Examination and Notices process in a credit union rolling out a special-purpose credit program, given small-business decline comparative file set. 2. A HMDA resubmission that still fails quality edits is the event in small-business decline comparative file set that forces Remove access or reverse the item for second-review underwriter under Fair Lending. 3. Small-business decline comparative file set shows a one-file miss after a HMDA resubmission that still fails quality edits, not a Examination and Notices program failure. 4. Small-business decline comparative file set cannot decide pricing disparities are justified yet after a HMDA resubmission that still fails quality edits; hold is the only Fair Lending close a credit union rolling out a special-purpose credit program can defend.

ANALYSIS REQUIRED 1. Flag any disparate-impact table second-review underwriter cannot explain from small-business decline comparative file set. 2. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 3. Match the adverse-action language to the facts in small-business decline comparative file set. 4. For this Fair Lending Examination and Notices file, read small-business decline comparative file set against a HMDA resubmission that still fails quality edits 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 / Examination and Notices packet (small-business decline comparative file set after a HMDA resubmission that still fails quality edits). If small-business decline comparative file set cannot force a Fair Lending label under Examination and Notices, stop. Do not invent missing evidence a credit union rolling out a special-purpose credit program does not have.