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

Situation

Geographic application and origination heat map arrived with an underwriter chat that used coded language for fair-lending officer. That is a Fair Lending CRA and Special-Purpose Programs decision on a special-purpose program is in a bank with thin HMDA LAR quality.

Decision

Fair-lending officer in a bank with thin HMDA LAR quality must choose A special-purpose program is well designed / A pretext using geographic application and origination heat map after an underwriter chat that used coded language.

Hypotheses to test

• Geographic application and origination heat map reads as A special-purpose program is well designed once an underwriter chat that used coded language is lined up to the same Fair Lending population.
• Geographic application and origination heat map is closer to A pretext after an underwriter chat that used coded language; A special-purpose program is well designed would over-claim this CRA and Special-Purpose Programs extract.
• A dual reading is still live in geographic application and origination heat map for fair-lending officer in a bank with thin HMDA LAR quality.
• Geographic application and origination heat map is missing the fact fair-lending officer needs after an underwriter chat that used coded language; stop this Fair Lending close.

Analysis required

• Match the adverse-action language to the facts in geographic application and origination heat map.
• Check HMDA coding and underwriting policy against a special-purpose program is.
• Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language.
• For this Fair Lending CRA and Special-Purpose Programs file, read geographic application and origination heat map against an underwriter chat that used coded language 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 (geographic application and origination heat map after an underwriter chat that used coded language). If geographic application and origination heat map cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If geographic application and origination heat map after an underwriter chat that used coded language 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.