Assess whether a special-purpose program is well designed or a pretext

SITUATION The working file is mortgage pricing residual by prohibited-basis group after a SPCP that originated almost no loans to the intended class. Adverse-action notice operations lead in a credit union rolling out a special-purpose credit program has to name A special-purpose program is well designed or A pretext for this Fair Lending Pricing and Credit Limits file.

DECISION Adverse-action notice operations lead in a credit union rolling out a special-purpose credit program must choose A special-purpose program is well designed / A pretext using mortgage pricing residual by prohibited-basis group after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. Authorize A special-purpose program is well designed now; mortgage pricing residual by prohibited-basis group already has the discriminator after a SPCP that originated almost no loans to the intended class. 2. Keep A pretext in force until mortgage pricing residual by prohibited-basis group is completed after a SPCP that originated almost no loans to the intended class for adverse-action notice operations lead. 3. Treat mortgage pricing residual by prohibited-basis group as A special-purpose program is well designed because both readings appear after a SPCP that originated almost no loans to the intended class. 4. Refuse a Fair Lending close: adverse-action notice operations lead does not have the decision a special-purpose program is turns on in mortgage pricing residual by prohibited-basis group.

ANALYSIS REQUIRED 1. Compare mortgage pricing residual by prohibited-basis group 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 adverse-action notice operations lead cannot explain from mortgage pricing residual by prohibited-basis group. 3. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 4. For this Fair Lending Pricing and Credit Limits file, read mortgage pricing residual by prohibited-basis group against a SPCP that originated almost no loans to the intended class and write the one fact that would move a special-purpose program is for adverse-action notice operations lead.

RECOMMENDATION Choose A special-purpose program is well designed / A pretext on this Fair Lending / Pricing and Credit Limits packet (mortgage pricing residual by prohibited-basis group after a SPCP that originated almost no loans to the intended class). Lead with the Fair Lending option mortgage pricing residual by prohibited-basis group can support after a SPCP that originated almost no loans to the intended class, then the two facts that force it, then the Monday action for adverse-action notice operations lead in a credit union rolling out a special-purpose credit program.