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

Situation

A credit union rolling out a special-purpose credit program cannot treat a HMDA resubmission that still fails quality edits as color commentary on small-business decline comparative file set. HMDA data-quality manager must close a special-purpose program is from that extract under Fair Lending / CRA and Special-Purpose Programs.

Decision

HMDA data-quality manager in a credit union rolling out a special-purpose credit program must choose A special-purpose program is well designed / A pretext using small-business decline comparative file set after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• HMDA data-quality manager can defend A special-purpose program is well designed from small-business decline comparative file set after a HMDA resubmission that still fails quality edits in a Fair Lending challenge.
• HMDA data-quality manager cannot defend A special-purpose program is well designed from small-business decline comparative file set; A pretext is what the extract actually supports after a HMDA resubmission that still fails quality edits.
• A HMDA resubmission that still fails quality edits never reached the population in small-business decline comparative file set — reopen intake, do not close a special-purpose program is.
• Two facts in small-business decline comparative file set after a HMDA resubmission that still fails quality edits conflict for HMDA data-quality manager; hold this CRA and Special-Purpose Programs file.

Analysis required

• Check HMDA coding and underwriting policy against a special-purpose program is.
• Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits.
• Flag any disparate-impact table HMDA data-quality manager cannot explain from small-business decline comparative file set.
• For this Fair Lending CRA and Special-Purpose Programs file, read small-business decline comparative file set against a HMDA resubmission that still fails quality edits and write the one fact that would move a special-purpose program is for HMDA data-quality manager.

Recommendation

Choose A special-purpose program is well designed / A pretext on this Fair Lending / CRA and Special-Purpose Programs packet (small-business decline comparative file set after a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option small-business decline comparative file set can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for HMDA data-quality manager in a credit union rolling out a special-purpose credit program.