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

Situation

Redlining and HMDA Data work in an institution preparing for a redlining exam now turns on a special-purpose program is because an exception rate twice as high for one group after credit controls put credit-card limit assignment disparity table in play. CRA strategist should say what credit-card limit assignment disparity table proves.

Decision

CRA strategist in an institution preparing for a redlining exam must choose A special-purpose program is well designed / A pretext using credit-card limit assignment disparity table after an exception rate twice as high for one group after credit controls.

Hypotheses to test

• CRA strategist can defend A special-purpose program is well designed from credit-card limit assignment disparity table after an exception rate twice as high for one group after credit controls in a Fair Lending challenge.
• CRA strategist cannot defend A special-purpose program is well designed from credit-card limit assignment disparity table; A pretext is what the extract actually supports after an exception rate twice as high for one group after credit controls.
• An exception rate twice as high for one group after credit controls never reached the population in credit-card limit assignment disparity table — reopen intake, do not close a special-purpose program is.
• Two facts in credit-card limit assignment disparity table after an exception rate twice as high for one group after credit controls conflict for CRA strategist; hold this Redlining and HMDA Data file.

Analysis required

• Flag any disparate-impact table CRA strategist cannot explain from credit-card limit assignment disparity table.
• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• Match the adverse-action language to the facts in credit-card limit assignment disparity table.
• For this Fair Lending Redlining and HMDA Data file, read credit-card limit assignment disparity table 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 CRA strategist.

Recommendation

Choose A special-purpose program is well designed / A pretext on this Fair Lending / Redlining and HMDA Data packet (credit-card limit assignment disparity table after an exception rate twice as high for one group after credit controls). Lead with the Fair Lending option credit-card limit assignment disparity table can support after an exception rate twice as high for one group after credit controls, then the two facts that force it, then the Monday action for CRA strategist in an institution preparing for a redlining exam.