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 community complaint about appraisal gaps as color commentary on manufactured-housing dealer overlay notes. 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 manufactured-housing dealer overlay notes after a community complaint about appraisal gaps.

Hypotheses to test

• Authorize A special-purpose program is well designed now; manufactured-housing dealer overlay notes already has the discriminator after a community complaint about appraisal gaps.
• Keep A pretext in force until manufactured-housing dealer overlay notes is completed after a community complaint about appraisal gaps for HMDA data-quality manager.
• Treat manufactured-housing dealer overlay notes as A special-purpose program is well designed because both readings appear after a community complaint about appraisal gaps.
• Refuse a Fair Lending close: HMDA data-quality manager does not have the page a special-purpose program is turns on in manufactured-housing dealer overlay notes.

Analysis required

• Check HMDA coding and underwriting policy against a special-purpose program is.
• Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps.
• Flag any disparate-impact table HMDA data-quality manager cannot explain from manufactured-housing dealer overlay notes.
• For this Fair Lending CRA and Special-Purpose Programs file, read manufactured-housing dealer overlay notes against a community complaint about appraisal gaps 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 (manufactured-housing dealer overlay notes after a community complaint about appraisal gaps). Lead with the Fair Lending option manufactured-housing dealer overlay notes can support after a community complaint about appraisal gaps, 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.