Whether pricing disparities are justified by legitimate factors from mortgage

Situation

Pricing disparities are justified sits with HMDA data-quality manager because a DOJ or CFPB monitor request for pricing files hit a credit-card issuer changing line-assignment logic. Evidence is mortgage pricing residual by prohibited-basis group; write the Fair Lending Redlining and HMDA Data option that extract can carry.

Decision

HMDA data-quality manager in a credit-card issuer changing line-assignment logic must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using mortgage pricing residual by prohibited-basis group after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• A DOJ or CFPB monitor request for pricing files is noise around an already-controlled Redlining and HMDA Data process in a credit-card issuer changing line-assignment logic, given mortgage pricing residual by prohibited-basis group.
• A DOJ or CFPB monitor request for pricing files is the event in mortgage pricing residual by prohibited-basis group that forces Remove access or reverse the item for HMDA data-quality manager under Fair Lending.
• Mortgage pricing residual by prohibited-basis group shows a one-file miss after a DOJ or CFPB monitor request for pricing files, not a Redlining and HMDA Data program failure.
• Mortgage pricing residual by prohibited-basis group cannot decide pricing disparities are justified yet after a DOJ or CFPB monitor request for pricing files; hold is the only Fair Lending close a credit-card issuer changing line-assignment logic can defend.

Analysis required

• Flag any disparate-impact table HMDA data-quality manager cannot explain from mortgage pricing residual by prohibited-basis group.
• Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend.
• Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group.
• For this Fair Lending Redlining and HMDA Data file, read mortgage pricing residual by prohibited-basis group against a DOJ or CFPB monitor request for pricing files 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 / Redlining and HMDA Data packet (mortgage pricing residual by prohibited-basis group after a DOJ or CFPB monitor request for pricing files). The follow-on Redlining and HMDA Data action is what HMDA data-quality manager does next: implement the option, assign an owner, and log the missing fact.