Assess whether pricing disparities are justified by legitimate factors

SITUATION A manufactured-housing lender with dealer-originated files cannot treat a SPCP that originated almost no loans to the intended class as incidental context on manufactured-housing dealer overlay notes. CRA strategist must close pricing disparities are justified from that extract under Fair Lending / Pricing and Credit Limits.

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 manufactured-housing dealer overlay notes after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. Manufactured-housing dealer overlay notes reads as Remove access or reverse the item once a SPCP that originated almost no loans to the intended class is lined up to the same Fair Lending population. 2. Manufactured-housing dealer overlay notes is closer to Temporary compensating control after a SPCP that originated almost no loans to the intended class; Remove access or reverse the item would over-claim this Pricing and Credit Limits extract. 3. Approve a documented exception is still live in manufactured-housing dealer overlay notes for CRA strategist in a manufactured-housing lender with dealer-originated files. 4. Manufactured-housing dealer overlay notes is missing the fact CRA strategist needs after a SPCP that originated almost no loans to the intended class; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Flag any disparate-impact table CRA strategist cannot explain from manufactured-housing dealer overlay notes. 2. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 3. Match the adverse-action language to the facts in manufactured-housing dealer overlay notes. 4. For this Fair Lending Pricing and Credit Limits file, read manufactured-housing dealer overlay notes 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 Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Pricing and Credit Limits packet (manufactured-housing dealer overlay notes after a SPCP that originated almost no loans to the intended class). Lead with the Fair Lending option manufactured-housing dealer overlay notes can support after a SPCP that originated almost no loans to the intended class, then the two facts that force it, then the Monday action for CRA strategist in a manufactured-housing lender with dealer-originated files.