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

Situation

In a small-business desk using a new vendor score, small-business decline comparative file set is the evidence after an underwriter chat that used coded language. HMDA data-quality manager has to pick A special-purpose program is well designed or A pretext for this Fair Lending Examination and Notices close using small-business decline comparative file set.

Decision

HMDA data-quality manager in a small-business desk using a new vendor score must choose A special-purpose program is well designed / A pretext using small-business decline comparative file set after an underwriter chat that used coded language.

Hypotheses to test

• Small-business decline comparative file set 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.
• Small-business decline comparative file set is closer to A pretext after an underwriter chat that used coded language; A special-purpose program is well designed would over-claim this Examination and Notices extract.
• A dual reading is still live in small-business decline comparative file set for HMDA data-quality manager in a small-business desk using a new vendor score.
• Small-business decline comparative file set is missing the fact HMDA data-quality manager needs after an underwriter chat that used coded language; stop this Fair Lending close.

Analysis required

• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• Match the adverse-action language to the facts in small-business decline comparative file set.
• Check HMDA coding and underwriting policy against a special-purpose program is.
• For this Fair Lending Examination and Notices file, read small-business decline comparative file set against an underwriter chat that used coded language 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 / Examination and Notices packet (small-business decline comparative file set after an underwriter chat that used coded language). The follow-on Examination and Notices action is what HMDA data-quality manager does next: implement the option, assign an owner, and log the missing fact.