CRA strategist must resolve whether pricing disparities are justified by

Situation

In a manufactured-housing lender with dealer-originated files, credit-card limit assignment disparity table is the evidence after a SPCP that originated almost no loans to the intended class. CRA strategist has to pick Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits close using credit-card limit assignment disparity table.

Decision

CRA strategist 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 credit-card limit assignment disparity table after a SPCP that originated almost no loans to the intended class.

Hypotheses to test

• A SPCP that originated almost no loans to the intended class is noise around an already-controlled Pricing and Credit Limits process in a manufactured-housing lender with dealer-originated files, given credit-card limit assignment disparity table.
• A SPCP that originated almost no loans to the intended class is the event in credit-card limit assignment disparity table that forces Remove access or reverse the item for CRA strategist under Fair Lending.
• Credit-card limit assignment disparity table shows a one-file miss after a SPCP that originated almost no loans to the intended class, not a Pricing and Credit Limits program failure.
• Credit-card limit assignment disparity table cannot decide pricing disparities are justified yet after a SPCP that originated almost no loans to the intended class; hold is the only Fair Lending close a manufactured-housing lender with dealer-originated files can defend.

Analysis required

• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• Match the adverse-action language to the facts in credit-card limit assignment disparity table.
• Check HMDA coding and underwriting policy against pricing disparities are justified.
• For this Fair Lending Pricing and Credit Limits file, read credit-card limit assignment disparity table against a SPCP that originated almost no loans to the intended class and write the one fact that would move pricing disparities are justified for CRA strategist.

Recommendation