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

Situation

CRA and Special-Purpose Programs work in a credit union rolling out a special-purpose credit program now turns on a special-purpose program is because a community complaint about appraisal gaps put HMDA LAR validity and quality edits in play. HMDA data-quality manager should say what HMDA LAR validity and quality edits proves.

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 HMDA LAR validity and quality edits after a community complaint about appraisal gaps.

Hypotheses to test

• Authorize A special-purpose program is well designed now; HMDA LAR validity and quality edits already has the discriminator after a community complaint about appraisal gaps.
• Keep A pretext in force until HMDA LAR validity and quality edits is completed after a community complaint about appraisal gaps for HMDA data-quality manager.
• Treat HMDA LAR validity and quality edits 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 HMDA LAR validity and quality edits.

Analysis required

• Compare HMDA LAR validity and quality edits 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 HMDA LAR validity and quality edits.
• Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend.
• For this Fair Lending CRA and Special-Purpose Programs file, read HMDA LAR validity and quality edits 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 (HMDA LAR validity and quality edits after a community complaint about appraisal gaps). The follow-on CRA and Special-Purpose Programs action is what HMDA data-quality manager does next: implement the option, assign an owner, and log the missing fact.