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

Situation

Examination and Notices work in a mortgage company after a pricing-regression spike now turns on a special-purpose program is because a CRA PE that called the assessment area too narrow put geographic application and origination heat map in play. Exam-response coordinator should say what geographic application and origination heat map proves.

Decision

Exam-response coordinator in a mortgage company after a pricing-regression spike must choose A special-purpose program is well designed / A pretext using geographic application and origination heat map after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• A CRA PE that called the assessment area too narrow is noise around an already-controlled Examination and Notices process in a mortgage company after a pricing-regression spike, given geographic application and origination heat map.
• A CRA PE that called the assessment area too narrow is the event in geographic application and origination heat map that forces A special-purpose program is well designed for exam-response coordinator under Fair Lending.
• Geographic application and origination heat map shows a one-file miss after a CRA PE that called the assessment area too narrow, not a Examination and Notices program failure.
• Geographic application and origination heat map cannot decide a special-purpose program is yet after a CRA PE that called the assessment area too narrow; hold is the only Fair Lending close a mortgage company after a pricing-regression spike can defend.

Analysis required

• Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow.
• Flag any disparate-impact table exam-response coordinator cannot explain from geographic application and origination heat map.
• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• For this Fair Lending Examination and Notices file, read geographic application and origination heat map against a CRA PE that called the assessment area too narrow and write the one fact that would move a special-purpose program is for exam-response coordinator.

Recommendation