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

SITUATION A bank with thin HMDA LAR quality cannot treat a notice that cites 'other' as the principal reason 40% of the time as incidental context on manufactured-housing dealer overlay notes. Community-development lender must close a special-purpose program is from that extract under Fair Lending / Pricing and Credit Limits.

DECISION Community-development lender in a bank with thin HMDA LAR quality must choose A special-purpose program is well designed / A pretext using manufactured-housing dealer overlay notes after a notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. Manufactured-housing dealer overlay notes reads as A special-purpose program is well designed once a notice that cites 'other' as the principal reason 40% of the time is lined up to the same Fair Lending population. 2. Manufactured-housing dealer overlay notes is closer to A pretext after a notice that cites 'other' as the principal reason 40% of the time; A special-purpose program is well designed would over-claim this Pricing and Credit Limits extract. 3. A dual reading is still live in manufactured-housing dealer overlay notes for community-development lender in a bank with thin HMDA LAR quality. 4. Manufactured-housing dealer overlay notes is missing the fact community-development lender needs after a notice that cites 'other' as the principal reason 40% of the time; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time. 2. Flag any disparate-impact table community-development lender cannot explain from manufactured-housing dealer overlay notes. 3. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 4. For this Fair Lending Pricing and Credit Limits file, read manufactured-housing dealer overlay notes against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move a special-purpose program is for community-development lender.

RECOMMENDATION Choose A special-purpose program is well designed / A pretext on this Fair Lending / Pricing and Credit Limits packet (manufactured-housing dealer overlay notes after a notice that cites 'other' as the principal reason 40% of the time). Lead with the Fair Lending option manufactured-housing dealer overlay notes can support after a notice that cites 'other' as the principal reason 40% of the time, then the two facts that force it, then the Monday action for community-development lender in a bank with thin HMDA LAR quality.