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

Situation

Adverse-action notice operations lead owns a special-purpose program is inside a small-business desk using a new vendor score with appraisal-gap outcomes in majority-minority tracts as the only packet. A notice that cites 'other' as the principal reason 40% of the time is what changed the clock for this Fair Lending CRA and Special-Purpose Programs file.

Decision

Adverse-action notice operations lead in a small-business desk using a new vendor score must choose A special-purpose program is well designed / A pretext using appraisal-gap outcomes in majority-minority tracts after a notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• Adverse-action notice operations lead can defend A special-purpose program is well designed from appraisal-gap outcomes in majority-minority tracts after a notice that cites 'other' as the principal reason 40% of the time in a Fair Lending challenge.
• Adverse-action notice operations lead cannot defend A special-purpose program is well designed from appraisal-gap outcomes in majority-minority tracts; A pretext is what the extract actually supports after a notice that cites 'other' as the principal reason 40% of the time.
• A notice that cites 'other' as the principal reason 40% of the time never reached the population in appraisal-gap outcomes in majority-minority tracts — reopen intake, do not close a special-purpose program is.
• Two facts in appraisal-gap outcomes in majority-minority tracts after a notice that cites 'other' as the principal reason 40% of the time conflict for adverse-action notice operations lead; hold this CRA and Special-Purpose Programs file.

Analysis required

• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts.
• Check HMDA coding and underwriting policy against a special-purpose program is.
• For this Fair Lending CRA and Special-Purpose Programs file, read appraisal-gap outcomes in majority-minority tracts against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move a special-purpose program is for adverse-action notice operations lead.

Recommendation