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

Situation

A special-purpose program is sits with community-development lender because an exception rate twice as high for one group after credit controls hit an institution preparing for a redlining exam. Evidence is geographic application and origination heat map; write the Fair Lending CRA and Special-Purpose Programs option that extract can carry.

Decision

Community-development lender in an institution preparing for a redlining exam must choose A special-purpose program is well designed / A pretext using geographic application and origination heat map 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 an institution preparing for a redlining exam, given geographic application and origination heat map.
• An exception rate twice as high for one group after credit controls is the event in geographic application and origination heat map that forces A special-purpose program is well designed for community-development lender under Fair Lending.
• Geographic application and origination heat map 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.
• Geographic application and origination heat map 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 an institution preparing for a redlining exam can defend.

Analysis required

• Match the adverse-action language to the facts in geographic application and origination heat map.
• Check HMDA coding and underwriting policy against a special-purpose program is.
• Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls.
• For this Fair Lending CRA and Special-Purpose Programs file, read geographic application and origination heat map 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 community-development lender.

Recommendation