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

Situation

HMDA data-quality manager in a credit union rolling out a special-purpose credit program has one working extract — HMDA LAR validity and quality edits — after a DOJ or CFPB monitor request for pricing files. HMDA data-quality manager in a credit union rolling out a special-purpose credit program has HMDA LAR validity and quality edits after a DOJ or CFPB monitor request for pricing files. If that extract cannot support a special-purpose program is, the honest Fair Lending CRA and Special-Purpose Programs output is hold.

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 DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• HMDA data-quality manager can defend A special-purpose program is well designed from HMDA LAR validity and quality edits after a DOJ or CFPB monitor request for pricing files in a Fair Lending challenge.
• HMDA data-quality manager cannot defend A special-purpose program is well designed from HMDA LAR validity and quality edits; A pretext is what the extract actually supports after a DOJ or CFPB monitor request for pricing files.
• A DOJ or CFPB monitor request for pricing files never reached the population in HMDA LAR validity and quality edits — reopen intake, do not close a special-purpose program is.
• Two facts in HMDA LAR validity and quality edits after a DOJ or CFPB monitor request for pricing files conflict for HMDA data-quality manager; hold this CRA and Special-Purpose Programs file.

Analysis required

• Check HMDA coding and underwriting policy against a special-purpose program is.
• Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files.
• Flag any disparate-impact table HMDA data-quality manager cannot explain from HMDA LAR validity and quality edits.
• For this Fair Lending CRA and Special-Purpose Programs file, read HMDA LAR validity and quality edits against a DOJ or CFPB monitor request for pricing files and write the one fact that would move a special-purpose program is for HMDA data-quality manager.

Recommendation