Assess whether pricing disparities are justified by legitimate factors

SITUATION Community-development lender is responsible for pricing disparities are justified in a mortgage company after a pricing-regression spike, using SPCP written plan versus actual originations as the only working extract. A SPCP that originated almost no loans to the intended class is what reset the timeline for this Fair Lending Redlining and HMDA Data file.

DECISION Community-development lender in a mortgage company after a pricing-regression spike must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using SPCP written plan versus actual originations after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. The population in SPCP written plan versus actual originations is the one a SPCP that originated almost no loans to the intended class named, so Remove access or reverse the item follows for this Redlining and HMDA Data file. 2. The population in SPCP written plan versus actual originations is adjacent only to a SPCP that originated almost no loans to the intended class; Temporary compensating control is the honest Fair Lending call. 3. A mortgage company after a pricing-regression spike already contained a SPCP that originated almost no loans to the intended class before SPCP written plan versus actual originations arrived; no new Redlining and HMDA Data path. 4. Provenance on SPCP written plan versus actual originations after a SPCP that originated almost no loans to the intended class is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class. 2. Flag any disparate-impact table community-development lender cannot explain from SPCP written plan versus actual originations. 3. Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend. 4. For this Fair Lending Redlining and HMDA Data file, read SPCP written plan versus actual originations 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 community-development lender.

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 (SPCP written plan versus actual originations after a SPCP that originated almost no loans to the intended class). If SPCP written plan versus actual originations cannot force a Fair Lending label under Redlining and HMDA Data, stop. If SPCP written plan versus actual originations after a SPCP that originated almost no loans to the intended class cannot support Remove access or reverse the item versus Temporary compensating control on this Fair Lending Redlining and HMDA Data close, community-development lender must do not infer a control or scheme beyond the transaction and entitlement evidence.