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

Situation

A special-purpose program is sits with second-review underwriter because a notice that cites 'other' as the principal reason 40% of the time hit a small-business desk using a new vendor score. Evidence is adverse-action notice principal-reason sample; write the Fair Lending Redlining and HMDA Data option that extract can carry.

Decision

Second-review underwriter in a small-business desk using a new vendor score must choose A special-purpose program is well designed / A pretext using adverse-action notice principal-reason sample after a notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• Adverse-action notice principal-reason sample reads as A special-purpose program is well designed once a notice that cites 'other' as the principal reason 40% of the time is lined up to the same Fair Lending population.
• Adverse-action notice principal-reason sample is closer to A pretext after a notice that cites 'other' as the principal reason 40% of the time; A special-purpose program is well designed would over-claim this Redlining and HMDA Data extract.
• A dual reading is still live in adverse-action notice principal-reason sample for second-review underwriter in a small-business desk using a new vendor score.
• Adverse-action notice principal-reason sample is missing the fact second-review underwriter needs after a notice that cites 'other' as the principal reason 40% of the time; 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 adverse-action notice principal-reason sample.
• Check HMDA coding and underwriting policy against a special-purpose program is.
• For this Fair Lending Redlining and HMDA Data file, read adverse-action notice principal-reason sample 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 second-review underwriter.

Recommendation

Choose A special-purpose program is well designed / A pretext on this Fair Lending / Redlining and HMDA Data packet (adverse-action notice principal-reason sample after a notice that cites 'other' as the principal reason 40% of the time). Lead with the Fair Lending option adverse-action notice principal-reason sample 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 second-review underwriter in a small-business desk using a new vendor score.