Assess whether pricing disparities are justified by legitimate factors

SITUATION The working file is underwriting exception log by branch after a HMDA resubmission that still fails quality edits. HMDA data-quality manager in a lender expanding into majority-minority census tracts has to name Remove access or reverse the item or Temporary compensating control for this Fair Lending Pricing and Credit Limits file.

DECISION HMDA data-quality manager in a lender expanding into majority-minority census tracts must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using underwriting exception log by branch after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. The population in underwriting exception log by branch is the one a HMDA resubmission that still fails quality edits named, so Remove access or reverse the item follows for this Pricing and Credit Limits file. 2. The population in underwriting exception log by branch is adjacent only to a HMDA resubmission that still fails quality edits; Temporary compensating control is the honest Fair Lending call. 3. A lender expanding into majority-minority census tracts already contained a HMDA resubmission that still fails quality edits before underwriting exception log by branch arrived; no new Pricing and Credit Limits path. 4. Provenance on underwriting exception log by branch after a HMDA resubmission that still fails quality edits is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

ANALYSIS REQUIRED 1. Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits. 2. Flag any disparate-impact table HMDA data-quality manager cannot explain from underwriting exception log by branch. 3. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 4. For this Fair Lending Pricing and Credit Limits file, read underwriting exception log by branch against a HMDA resubmission that still fails quality edits 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 / Pricing and Credit Limits packet (underwriting exception log by branch after a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option underwriting exception log by branch can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for HMDA data-quality manager in a lender expanding into majority-minority census tracts.