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

Situation

A SPCP that originated almost no loans to the intended class put appraisal-gap outcomes in majority-minority tracts in front of CRA strategist in a manufactured-housing lender with dealer-originated files. This Fair Lending / Pricing and Credit Limits 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

CRA strategist 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 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 Pricing and Credit Limits process in a manufactured-housing lender with dealer-originated files, given appraisal-gap outcomes in majority-minority tracts.
• A SPCP that originated almost no loans to the intended class is the event in appraisal-gap outcomes in majority-minority tracts that forces A special-purpose program is well designed for CRA strategist under Fair Lending.
• Appraisal-gap outcomes in majority-minority tracts shows a one-file miss after a SPCP that originated almost no loans to the intended class, not a Pricing and Credit Limits program failure.
• Appraisal-gap outcomes in majority-minority tracts 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 manufactured-housing lender with dealer-originated files can defend.

Analysis required

• Compare appraisal-gap outcomes in majority-minority tracts 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 CRA strategist 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.
• For this Fair Lending Pricing and Credit Limits file, read appraisal-gap outcomes in majority-minority tracts 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 CRA strategist.