Assess whether pricing disparities are justified by legitimate factors

SITUATION HMDA data-quality manager in a credit union rolling out a special-purpose credit program has one working extract — underwriting exception log by branch — after an underwriter chat that used coded language. If underwriting exception log by branch cannot support pricing disparities are justified, the only defensible Fair Lending output is hold.

DECISION HMDA data-quality manager 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 underwriting exception log by branch after an underwriter chat that used coded language.

HYPOTHESES TO TEST 1. HMDA data-quality manager can defend Remove access or reverse the item from underwriting exception log by branch after an underwriter chat that used coded language in a Fair Lending challenge. 2. HMDA data-quality manager cannot defend Remove access or reverse the item from underwriting exception log by branch; Temporary compensating control is what the extract actually supports after an underwriter chat that used coded language. 3. An underwriter chat that used coded language never reached the population in underwriting exception log by branch — reopen intake, do not close pricing disparities are justified. 4. Two facts in underwriting exception log by branch after an underwriter chat that used coded language conflict for HMDA data-quality manager; hold this CRA and Special-Purpose Programs file.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in underwriting exception log by branch. 2. Check HMDA coding and underwriting policy against pricing disparities are justified. 3. Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language. 4. For this Fair Lending CRA and Special-Purpose Programs file, read underwriting exception log by branch against an underwriter chat that used coded language and write the one fact that would move pricing disparities are justified for HMDA data-quality manager.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / CRA and Special-Purpose Programs packet (underwriting exception log by branch after an underwriter chat that used coded language). Lead with the Fair Lending option underwriting exception log by branch can support after an underwriter chat that used coded language, then the two facts that force it, then the Monday action for HMDA data-quality manager in a credit union rolling out a special-purpose credit program.