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

SITUATION After a notice that cites 'other' as the principal reason 40% of the time, small-business decline comparative file set is what fair-lending officer can touch in a mortgage company after a pricing-regression spike. Fair Lending will live with A special-purpose program is well designed versus A pretext on this Pricing and Credit Limits file.

DECISION Fair-lending officer in a mortgage company after a pricing-regression spike must choose A special-purpose program is well designed / A pretext using small-business decline comparative file set after a notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. The population in small-business decline comparative file set is the one a notice that cites 'other' as the principal reason 40% of the time named, so A special-purpose program is well designed follows for this Pricing and Credit Limits file. 2. The population in small-business decline comparative file set is adjacent only to a notice that cites 'other' as the principal reason 40% of the time; A pretext is the honest Fair Lending call. 3. A mortgage company after a pricing-regression spike already contained a notice that cites 'other' as the principal reason 40% of the time before small-business decline comparative file set arrived; no new Pricing and Credit Limits path. 4. Provenance on small-business decline comparative file set after a notice that cites 'other' as the principal reason 40% of the time is broken; do not pick A special-purpose program is well designed or A pretext yet.

ANALYSIS REQUIRED 1. Flag any disparate-impact table fair-lending officer cannot explain from small-business decline comparative file set. 2. Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend. 3. Match the adverse-action language to the facts in small-business decline comparative file set. 4. For this Fair Lending Pricing and Credit Limits file, read small-business decline comparative file set 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 / Pricing and Credit Limits packet (small-business decline comparative file set after a notice that cites 'other' as the principal reason 40% of the time). Lead with the Fair Lending option small-business decline comparative file set can support after a notice that cites 'other' as the principal reason 40% of the time, then the two facts that force it, then the Monday action for fair-lending officer in a mortgage company after a pricing-regression spike.