Assess whether pricing disparities are justified by legitimate factors

SITUATION Exam-response coordinator is responsible for pricing disparities are justified in a manufactured-housing lender, using dealer-originated files with underwriting exception log by branch as the only working extract. A community complaint about appraisal gaps is what reset the timeline for this Fair Lending CRA and Special-Purpose Programs file.

DECISION Exam-response coordinator in a manufactured-housing lender with dealer-originated files must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using underwriting exception log by branch after a community complaint about appraisal gaps.

HYPOTHESES TO TEST 1. Underwriting exception log by branch reads as Remove access or reverse the item once a community complaint about appraisal gaps is lined up to the same Fair Lending population. 2. Underwriting exception log by branch is closer to Temporary compensating control after a community complaint about appraisal gaps; Remove access or reverse the item would over-claim this CRA and Special-Purpose Programs extract. 3. Approve a documented exception is still live in underwriting exception log by branch for exam-response coordinator in a manufactured-housing lender with dealer-originated files. 4. Underwriting exception log by branch is missing the fact exam-response coordinator needs after a community complaint about appraisal gaps; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against pricing disparities are justified. 2. Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps. 3. Flag any disparate-impact table exam-response coordinator cannot explain from underwriting exception log by branch. 4. For this Fair Lending CRA and Special-Purpose Programs file, read underwriting exception log by branch against a community complaint about appraisal gaps and write the one fact that would move pricing disparities are justified for exam-response coordinator.

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 community complaint about appraisal gaps). The follow-on CRA and Special-Purpose Programs action is what exam-response coordinator does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on pricing disparities are justified, then the evidence in underwriting exception log by branch, then the action for exam-response coordinator - Hypothesis scorecard against underwriting exception log by branch: supported / rejected / untestable - Regulatory or exam hook CRA and Special-Purpose Programs would cite - CRA and Special-Purpose Programs finding in underwriting exception log by branch that a second reviewer can re-perform