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

Situation

A marketing mailer that skipped majority-minority tracts put appraisal-gap outcomes in majority-minority tracts in front of community-development lender in a manufactured-housing lender with dealer-originated files. This Fair Lending / Examination and Notices close is a special-purpose program is from appraisal-gap outcomes in majority-minority tracts, and the live options are A special-purpose program is well designed, A pretext.

Decision

Community-development lender in a manufactured-housing lender with dealer-originated files must choose A special-purpose program is well designed / A pretext using appraisal-gap outcomes in majority-minority tracts after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Community-development lender can defend A special-purpose program is well designed from appraisal-gap outcomes in majority-minority tracts after a marketing mailer that skipped majority-minority tracts in a Fair Lending challenge.
• Community-development lender 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 marketing mailer that skipped majority-minority tracts.
• A marketing mailer that skipped majority-minority tracts 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 marketing mailer that skipped majority-minority tracts conflict for community-development lender; hold this Examination and Notices file.

Analysis required

• Flag any disparate-impact table community-development lender cannot explain from appraisal-gap outcomes in majority-minority tracts.
• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts.
• For this Fair Lending Examination and Notices file, read appraisal-gap outcomes in majority-minority tracts against a marketing mailer that skipped majority-minority tracts and write the one fact that would move a special-purpose program is for community-development lender.

Recommendation