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

Situation

Redlining and HMDA Data work in a manufactured-housing lender with dealer-originated files now turns on a special-purpose program is because a branch that stopped taking applications in one ZIP put mortgage pricing residual by prohibited-basis group in play. Redlining and HMDA Data work in a manufactured-housing lender with dealer-originated files now turns on a special-purpose program is because a branch that stopped taking applications in one ZIP put mortgage pricing residual by prohibited-basis group in play; fair-lending officer should say what mortgage pricing residual by prohibited-basis group proves for Fair Lending.

Decision

Fair-lending officer in a manufactured-housing lender with dealer-originated files must choose A special-purpose program is well designed / A pretext using mortgage pricing residual by prohibited-basis group after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• Mortgage pricing residual by prohibited-basis group reads as A special-purpose program is well designed once a branch that stopped taking applications in one ZIP is lined up to the same Fair Lending population.
• Mortgage pricing residual by prohibited-basis group is closer to A pretext after a branch that stopped taking applications in one ZIP; A special-purpose program is well designed would over-claim this Redlining and HMDA Data extract.
• A dual reading is still live in mortgage pricing residual by prohibited-basis group for fair-lending officer in a manufactured-housing lender with dealer-originated files.
• Mortgage pricing residual by prohibited-basis group is missing the fact fair-lending officer needs after a branch that stopped taking applications in one ZIP; stop this Fair Lending close.

Analysis required

• Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP.
• Flag any disparate-impact table fair-lending officer cannot explain from mortgage pricing residual by prohibited-basis group.
• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• For this Fair Lending Redlining and HMDA Data file, read mortgage pricing residual by prohibited-basis group against a branch that stopped taking applications in one ZIP and write the one fact that would move a special-purpose program is for fair-lending officer.