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

Situation

A marketing mailer that skipped majority-minority tracts put small-business decline comparative file set in front of CRA strategist in a bank with thin HMDA LAR quality. This Fair Lending / Examination and Notices close is a special-purpose program is from small-business decline comparative file set, and the live options are A special-purpose program is well designed, A pretext.

Decision

CRA strategist in a bank with thin HMDA LAR quality must choose A special-purpose program is well designed / A pretext using small-business decline comparative file set after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Small-business decline comparative file set reads as A special-purpose program is well designed once a marketing mailer that skipped majority-minority tracts is lined up to the same Fair Lending population.
• Small-business decline comparative file set is closer to A pretext after a marketing mailer that skipped majority-minority tracts; A special-purpose program is well designed would over-claim this Examination and Notices extract.
• A dual reading is still live in small-business decline comparative file set for CRA strategist in a bank with thin HMDA LAR quality.
• Small-business decline comparative file set is missing the fact CRA strategist needs after a marketing mailer that skipped majority-minority tracts; stop this Fair Lending close.

Analysis required

• Match the adverse-action language to the facts in small-business decline comparative file set.
• Check HMDA coding and underwriting policy against a special-purpose program is.
• Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts.
• For this Fair Lending Examination and Notices file, read small-business decline comparative file set against a marketing mailer that skipped majority-minority tracts 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 / Examination and Notices packet (small-business decline comparative file set after a marketing mailer that skipped majority-minority tracts). The follow-on Examination and Notices action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.