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

Situation

CRA and Special-Purpose Programs work in a bank with thin HMDA LAR quality now turns on a special-purpose program is because a notice that cites 'other' as the principal reason 40% of the time put credit-card limit assignment disparity table in play. Fair-lending officer should say what credit-card limit assignment disparity table proves.

Decision

Fair-lending officer in a bank with thin HMDA LAR quality must choose A special-purpose program is well designed / A pretext using credit-card limit assignment disparity table after a notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• Fair-lending officer can defend A special-purpose program is well designed from credit-card limit assignment disparity table after a notice that cites 'other' as the principal reason 40% of the time in a Fair Lending challenge.
• Fair-lending officer 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 a notice that cites 'other' as the principal reason 40% of the time.
• A notice that cites 'other' as the principal reason 40% of the time 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 a notice that cites 'other' as the principal reason 40% of the time conflict for fair-lending officer; hold this CRA and Special-Purpose Programs file.

Analysis required

• Match the adverse-action language to the facts in credit-card limit assignment disparity table.
• Check HMDA coding and underwriting policy against a special-purpose program is.
• Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time.
• For this Fair Lending CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move a special-purpose program is for fair-lending officer.

Recommendation

Choose A special-purpose program is well designed / A pretext on this Fair Lending / CRA and Special-Purpose Programs packet (credit-card limit assignment disparity table after a notice that cites 'other' as the principal reason 40% of the time). If credit-card limit assignment disparity table cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If credit-card limit assignment disparity table after a notice that cites 'other' as the principal reason 40% of the time cannot support A special-purpose program is well designed versus A pretext on this Fair Lending CRA and Special-Purpose Programs close, fair-lending officer must do not infer a control or scheme beyond the transaction and entitlement evidence.