Exam-response coordinator must resolve whether pricing disparities are

Situation

Pricing disparities are justified sits with exam-response coordinator because a DOJ or CFPB monitor request for pricing files hit an institution preparing for a redlining exam. Evidence is model-reason-code mapping that does not match notices; write the Fair Lending Pricing and Credit Limits option that extract can carry.

Decision

Exam-response coordinator in an institution preparing for a redlining exam must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using model-reason-code mapping that does not match notices after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• The population in model-reason-code mapping that does not match notices is the one a DOJ or CFPB monitor request for pricing files named, so Remove access or reverse the item follows for this Pricing and Credit Limits file.
• The population in model-reason-code mapping that does not match notices is adjacent only to a DOJ or CFPB monitor request for pricing files; Temporary compensating control is the honest Fair Lending call.
• An institution preparing for a redlining exam already contained a DOJ or CFPB monitor request for pricing files before model-reason-code mapping that does not match notices arrived; no new Pricing and Credit Limits path.
• Provenance on model-reason-code mapping that does not match notices after a DOJ or CFPB monitor request for pricing files is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files.
• Flag any disparate-impact table exam-response coordinator cannot explain from model-reason-code mapping that does not match notices.
• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• For this Fair Lending Pricing and Credit Limits file, read model-reason-code mapping that does not match notices against a DOJ or CFPB monitor request for pricing files and write the one fact that would move pricing disparities are justified for exam-response coordinator.

Recommendation