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

Situation

A lender expanding into majority-minority census tracts cannot treat a vendor score change with no disparate-impact test as color commentary on CRA assessment-area versus lending footprint. Adverse-action notice operations lead must close a special-purpose program is from that extract under Fair Lending / Redlining and HMDA Data.

Decision

Adverse-action notice operations lead in a lender expanding into majority-minority census tracts must choose A special-purpose program is well designed / A pretext using CRA assessment-area versus lending footprint after a vendor score change with no disparate-impact test.

Hypotheses to test

• CRA assessment-area versus lending footprint reads as A special-purpose program is well designed once a vendor score change with no disparate-impact test is lined up to the same Fair Lending population.
• CRA assessment-area versus lending footprint is closer to A pretext after a vendor score change with no disparate-impact test; A special-purpose program is well designed would over-claim this Redlining and HMDA Data extract.
• A dual reading is still live in CRA assessment-area versus lending footprint for adverse-action notice operations lead in a lender expanding into majority-minority census tracts.
• CRA assessment-area versus lending footprint is missing the fact adverse-action notice operations lead needs after a vendor score change with no disparate-impact test; stop this Fair Lending close.

Analysis required

• Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend.
• Match the adverse-action language to the facts in CRA assessment-area versus lending footprint.
• Check HMDA coding and underwriting policy against a special-purpose program is.
• For this Fair Lending Redlining and HMDA Data file, read CRA assessment-area versus lending footprint against a vendor score change with no disparate-impact test and write the one fact that would move a special-purpose program is for adverse-action notice operations lead.

Recommendation

Choose A special-purpose program is well designed / A pretext on this Fair Lending / Redlining and HMDA Data packet (CRA assessment-area versus lending footprint after a vendor score change with no disparate-impact test). If CRA assessment-area versus lending footprint cannot force a Fair Lending label under Redlining and HMDA Data, stop. If CRA assessment-area versus lending footprint after a vendor score change with no disparate-impact test cannot support A special-purpose program is well designed versus A pretext on this Fair Lending Redlining and HMDA Data close, adverse-action notice operations lead must do not infer a control or scheme beyond the transaction and entitlement evidence.