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

Situation

The desk packet is manufactured-housing dealer overlay notes after a SPCP that originated almost no loans to the intended class. Second-review underwriter in a credit union rolling out a special-purpose credit program has to name A special-purpose program is well designed or A pretext for this Fair Lending Examination and Notices file.

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 manufactured-housing dealer overlay notes after a SPCP that originated almost no loans to the intended class.

Hypotheses to test

• Second-review underwriter can defend A special-purpose program is well designed from manufactured-housing dealer overlay notes after a SPCP that originated almost no loans to the intended class in a Fair Lending challenge.
• Second-review underwriter cannot defend A special-purpose program is well designed from manufactured-housing dealer overlay notes; A pretext is what the extract actually supports after a SPCP that originated almost no loans to the intended class.
• A SPCP that originated almost no loans to the intended class never reached the population in manufactured-housing dealer overlay notes — reopen intake, do not close a special-purpose program is.
• Two facts in manufactured-housing dealer overlay notes after a SPCP that originated almost no loans to the intended class conflict for second-review underwriter; hold this Examination and Notices file.

Analysis required

• Match the adverse-action language to the facts in manufactured-housing dealer overlay notes.
• 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 SPCP that originated almost no loans to the intended class.
• For this Fair Lending Examination and Notices file, read manufactured-housing dealer overlay notes against a SPCP that originated almost no loans to the intended class 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 (manufactured-housing dealer overlay notes after a SPCP that originated almost no loans to the intended class). Lead with the Fair Lending option manufactured-housing dealer overlay notes can support after a SPCP that originated almost no loans to the intended class, then the two facts that force it, then the Monday action for second-review underwriter in a credit union rolling out a special-purpose credit program.