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

Situation

A vendor score change with no disparate-impact test put geographic application and origination heat map in front of adverse-action notice operations lead in a small-business desk using a new vendor score. This Fair Lending / CRA and Special-Purpose Programs close is a special-purpose program is from geographic application and origination heat map, and the live options are A special-purpose program is well designed, A pretext.

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 geographic application and origination heat map after a vendor score change with no disparate-impact test.

Hypotheses to test

• A vendor score change with no disparate-impact test is noise around an already-controlled CRA and Special-Purpose Programs process in a small-business desk using a new vendor score, given geographic application and origination heat map.
• A vendor score change with no disparate-impact test is the event in geographic application and origination heat map that forces A special-purpose program is well designed for adverse-action notice operations lead under Fair Lending.
• Geographic application and origination heat map shows a one-file miss after a vendor score change with no disparate-impact test, not a CRA and Special-Purpose Programs program failure.
• Geographic application and origination heat map cannot decide a special-purpose program is yet after a vendor score change with no disparate-impact test; hold is the only Fair Lending close a small-business desk using a new vendor score can defend.

Analysis required

• Flag any disparate-impact table adverse-action notice operations lead cannot explain from geographic application and origination heat map.
• 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 geographic application and origination heat map.
• For this Fair Lending CRA and Special-Purpose Programs file, read geographic application and origination heat map against a vendor score change with no disparate-impact test and write the one fact that would move a special-purpose program is for adverse-action notice operations lead.

Recommendation