Compliance Board
Pricing & Terms
Evaluating interest rate basis point (bps) variance and discretionary broker/dealer markups across commercial credit tiers.
Net Portfolio Offered Spread
SPREAD ELEVATED
+44.0 bps
Internal Policy Ceiling: ≤ 25.0 bps
Average MWBE Offered APR
7.42%
Minority & Women-Owned Borrowers
Average Non-Minority APR
6.98%
Control Group Baseline Benchmark
Risk-Adjusted Pricing by Commercial Credit Tier
Comparing baseline automated rate assignment vs. net offered pricing across Paydex score brackets
| Commercial Credit Tier | Applications ($N$) | MWBE Avg APR | Control Avg APR | Net Spread (bps) | Internal Benchmark (≤ 25 bps) |
|---|
Underwriting Markup Finding:
All commercial credit tiers exhibit compliant pricing spreads within the ≤ 25 bps internal policy tolerance ceiling.
All commercial credit tiers exhibit compliant pricing spreads within the ≤ 25 bps internal policy tolerance ceiling.
Regional Offered APR & Geographic Rate Disparities
Evaluating basis point rate variances across regional branch and postal zone networks
| Geographic Postal Region | Applications ($N$) | MWBE Avg APR | Control Avg APR | Regional Spread | Policy Status |
|---|