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 branch that stopped taking applications in one ZIP hit a credit union rolling out a special-purpose credit program. Evidence is geographic application and origination heat map; write the Fair Lending Examination and Notices option that extract can carry.

Decision

Second-review underwriter in a credit union rolling out a special-purpose credit program must choose A special-purpose program is well designed / A pretext using geographic application and origination heat map after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• Authorize A special-purpose program is well designed now; geographic application and origination heat map already has the discriminator after a branch that stopped taking applications in one ZIP.
• Keep A pretext in force until geographic application and origination heat map is completed after a branch that stopped taking applications in one ZIP for second-review underwriter.
• Treat geographic application and origination heat map as A special-purpose program is well designed because both readings appear after a branch that stopped taking applications in one ZIP.
• Refuse a Fair Lending close: second-review underwriter does not have the page a special-purpose program is turns on in geographic application and origination heat map.

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 a branch that stopped taking applications in one ZIP.
• For this Fair Lending Examination and Notices file, read geographic application and origination heat map against a branch that stopped taking applications in one ZIP 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 / Examination and Notices packet (geographic application and origination heat map after a branch that stopped taking applications in one ZIP). The follow-on Examination and Notices action is what second-review underwriter does next: implement the option, assign an owner, and log the missing fact.