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

Situation

In a bank with thin HMDA LAR quality, model-reason-code mapping that does not match notices is the evidence after a SPCP that originated almost no loans to the intended class. Exam-response coordinator has to pick A special-purpose program is well designed or A pretext for this Fair Lending Redlining and HMDA Data close using model-reason-code mapping that does not match notices.

Decision

Exam-response coordinator in a bank with thin HMDA LAR quality must choose A special-purpose program is well designed / A pretext using model-reason-code mapping that does not match notices 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 Redlining and HMDA Data process in a bank with thin HMDA LAR quality, given model-reason-code mapping that does not match notices.
• A SPCP that originated almost no loans to the intended class is the event in model-reason-code mapping that does not match notices that forces A special-purpose program is well designed for exam-response coordinator under Fair Lending.
• Model-reason-code mapping that does not match notices shows a one-file miss after a SPCP that originated almost no loans to the intended class, not a Redlining and HMDA Data program failure.
• Model-reason-code mapping that does not match notices 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 bank with thin HMDA LAR quality can defend.

Analysis required

• Match the adverse-action language to the facts in model-reason-code mapping that does not match notices.
• Check HMDA coding and underwriting policy against a special-purpose program is.
• Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class.
• For this Fair Lending Redlining and HMDA Data file, read model-reason-code mapping that does not match notices 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 exam-response coordinator.

Recommendation