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

Situation

Appraisal-gap outcomes in majority-minority tracts arrived with a CRA PE that called the assessment area too narrow for CRA strategist. That is a Fair Lending Examination and Notices decision on a special-purpose program is in a bank with thin HMDA LAR quality.

Decision

CRA strategist in a bank with thin HMDA LAR quality must choose A special-purpose program is well designed / A pretext using appraisal-gap outcomes in majority-minority tracts after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• The population in appraisal-gap outcomes in majority-minority tracts is the one a CRA PE that called the assessment area too narrow named, so A special-purpose program is well designed follows for this Examination and Notices file.
• The population in appraisal-gap outcomes in majority-minority tracts is adjacent only to a CRA PE that called the assessment area too narrow; A pretext is the honest Fair Lending call.
• A bank with thin HMDA LAR quality already contained a CRA PE that called the assessment area too narrow before appraisal-gap outcomes in majority-minority tracts arrived; no new Examination and Notices path.
• Provenance on appraisal-gap outcomes in majority-minority tracts after a CRA PE that called the assessment area too narrow is broken; do not pick A special-purpose program is well designed or A pretext yet.

Analysis required

• Test a documented exception versus a pattern a bank with thin HMDA LAR quality 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 Examination and Notices file, read appraisal-gap outcomes in majority-minority tracts against a CRA PE that called the assessment area too narrow and write the one fact that would move a special-purpose program is for CRA strategist.

Recommendation

Choose A special-purpose program is well designed / A pretext on this Fair Lending / Examination and Notices packet (appraisal-gap outcomes in majority-minority tracts after a CRA PE that called the assessment area too narrow). Lead with the Fair Lending option appraisal-gap outcomes in majority-minority tracts can support after a CRA PE that called the assessment area too narrow, then the two facts that force it, then the Monday action for CRA strategist in a bank with thin HMDA LAR quality.