Assess whether pricing disparities are justified by legitimate factors

SITUATION After a CRA PE that called the assessment area too narrow, underwriting exception log by branch is what HMDA data-quality manager 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 CRA and Special-Purpose Programs file.

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 a CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. HMDA data-quality manager can defend Remove access or reverse the item from underwriting exception log by branch after a CRA PE that called the assessment area too narrow 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 a CRA PE that called the assessment area too narrow. 3. A CRA PE that called the assessment area too narrow 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 a CRA PE that called the assessment area too narrow conflict for HMDA data-quality manager; hold this CRA and Special-Purpose Programs file.

ANALYSIS REQUIRED 1. Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow. 2. Flag any disparate-impact table HMDA data-quality manager cannot explain from underwriting exception log by branch. 3. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 4. For this Fair Lending CRA and Special-Purpose Programs file, read underwriting exception log by branch against a CRA PE that called the assessment area too narrow 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 a CRA PE that called the assessment area too narrow). Lead with the Fair Lending option underwriting exception log by branch 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 HMDA data-quality manager in a credit union rolling out a special-purpose credit program.