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

Situation

In an institution preparing for a redlining exam, geographic application and origination heat map is the evidence after a HMDA resubmission that still fails quality edits. Fair-lending officer has to pick A special-purpose program is well designed or A pretext for this Fair Lending Examination and Notices close using geographic application and origination heat map.

Decision

Fair-lending officer in an institution preparing for a redlining exam must choose A special-purpose program is well designed / A pretext using geographic application and origination heat map after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• A HMDA resubmission that still fails quality edits is noise around an already-controlled Examination and Notices process in an institution preparing for a redlining exam, given geographic application and origination heat map.
• A HMDA resubmission that still fails quality edits is the event in geographic application and origination heat map that forces A special-purpose program is well designed for fair-lending officer under Fair Lending.
• Geographic application and origination heat map shows a one-file miss after a HMDA resubmission that still fails quality edits, not a Examination and Notices program failure.
• Geographic application and origination heat map cannot decide a special-purpose program is yet after a HMDA resubmission that still fails quality edits; hold is the only Fair Lending close an institution preparing for a redlining exam can defend.

Analysis required

• Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits.
• Flag any disparate-impact table fair-lending officer cannot explain from geographic application and origination heat map.
• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• For this Fair Lending Examination and Notices file, read geographic application and origination heat map against a HMDA resubmission that still fails quality edits 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 / Examination and Notices packet (geographic application and origination heat map after a HMDA resubmission that still fails quality edits). If geographic application and origination heat map cannot force a Fair Lending label under Examination and Notices, stop. If geographic application and origination heat map after a HMDA resubmission that still fails quality edits cannot support A special-purpose program is well designed versus A pretext on this Fair Lending Examination and Notices close, fair-lending officer must do not infer a control or scheme beyond the transaction and entitlement evidence.