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

Situation

Adverse-action notice operations lead in a small-business desk using a new vendor score has one working extract — manufactured-housing dealer overlay notes — after an exception rate twice as high for one group after credit controls. Adverse-action notice operations lead in a small-business desk using a new vendor score has manufactured-housing dealer overlay notes after an exception rate twice as high for one group after credit controls. If that extract cannot support a special-purpose program is, the honest Fair Lending CRA and Special-Purpose Programs output is hold.

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 manufactured-housing dealer overlay notes after an exception rate twice as high for one group after credit controls.

Hypotheses to test

• An exception rate twice as high for one group after credit controls is noise around an already-controlled CRA and Special-Purpose Programs process in a small-business desk using a new vendor score, given manufactured-housing dealer overlay notes.
• An exception rate twice as high for one group after credit controls is the event in manufactured-housing dealer overlay notes that forces A special-purpose program is well designed for adverse-action notice operations lead under Fair Lending.
• Manufactured-housing dealer overlay notes shows a one-file miss after an exception rate twice as high for one group after credit controls, not a CRA and Special-Purpose Programs program failure.
• Manufactured-housing dealer overlay notes cannot decide a special-purpose program is yet after an exception rate twice as high for one group after credit controls; hold is the only Fair Lending close a small-business desk using a new vendor score can defend.

Analysis required

• Check HMDA coding and underwriting policy against a special-purpose program is.
• Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls.
• Flag any disparate-impact table adverse-action notice operations lead cannot explain from manufactured-housing dealer overlay notes.
• For this Fair Lending CRA and Special-Purpose Programs file, read manufactured-housing dealer overlay notes against an exception rate twice as high for one group after credit controls and write the one fact that would move a special-purpose program is for adverse-action notice operations lead.