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

Situation

The desk packet is credit-card limit assignment disparity table after a SPCP that originated almost no loans to the intended class. Community-development lender in a mortgage company after a pricing-regression spike has to name A special-purpose program is well designed or A pretext for this Fair Lending Redlining and HMDA Data file.

Decision

Community-development lender in a mortgage company after a pricing-regression spike must choose A special-purpose program is well designed / A pretext using credit-card limit assignment disparity table after a SPCP that originated almost no loans to the intended class.

Hypotheses to test

• A SPCP that originated almost no loans to the intended class is noise around an already-controlled Redlining and HMDA Data process in a mortgage company after a pricing-regression spike, given credit-card limit assignment disparity table.
• A SPCP that originated almost no loans to the intended class is the event in credit-card limit assignment disparity table that forces A special-purpose program is well designed for community-development lender under Fair Lending.
• Credit-card limit assignment disparity table shows a one-file miss after a SPCP that originated almost no loans to the intended class, not a Redlining and HMDA Data program failure.
• Credit-card limit assignment disparity table cannot decide a special-purpose program is yet after a SPCP that originated almost no loans to the intended class; hold is the only Fair Lending close a mortgage company after a pricing-regression spike can defend.

Analysis required

• Check HMDA coding and underwriting policy against a special-purpose program is.
• Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class.
• Flag any disparate-impact table community-development lender cannot explain from credit-card limit assignment disparity table.
• For this Fair Lending Redlining and HMDA Data file, read credit-card limit assignment disparity table against a SPCP that originated almost no loans to the intended class and write the one fact that would move a special-purpose program is for community-development lender.

Recommendation