CRA strategist must resolve whether a special-purpose program is well

Situation

CRA strategist in a manufactured-housing lender with dealer-originated files has one working extract — model-reason-code mapping that does not match notices — after a community complaint about appraisal gaps. If model-reason-code mapping that does not match notices cannot support a special-purpose program is, the honest Fair Lending output is hold.

Decision

CRA strategist in a manufactured-housing lender with dealer-originated files must choose A special-purpose program is well designed / A pretext using model-reason-code mapping that does not match notices after a community complaint about appraisal gaps.

Hypotheses to test

• Model-reason-code mapping that does not match notices reads as A special-purpose program is well designed once a community complaint about appraisal gaps is lined up to the same Fair Lending population.
• Model-reason-code mapping that does not match notices is closer to A pretext after a community complaint about appraisal gaps; A special-purpose program is well designed would over-claim this Pricing and Credit Limits extract.
• A dual reading is still live in model-reason-code mapping that does not match notices for CRA strategist in a manufactured-housing lender with dealer-originated files.
• Model-reason-code mapping that does not match notices is missing the fact CRA strategist needs after a community complaint about appraisal gaps; stop this Fair Lending close.

Analysis required

• Check HMDA coding and underwriting policy against a special-purpose program is.
• Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps.
• Flag any disparate-impact table CRA strategist cannot explain from model-reason-code mapping that does not match notices.
• For this Fair Lending Pricing and Credit Limits file, read model-reason-code mapping that does not match notices against a community complaint about appraisal gaps and write the one fact that would move a special-purpose program is for CRA strategist.

Recommendation

Choose A special-purpose program is well designed / A pretext on this Fair Lending / Pricing and Credit Limits packet (model-reason-code mapping that does not match notices after a community complaint about appraisal gaps). Lead with the Fair Lending option model-reason-code mapping that does not match notices can support after a community complaint about appraisal gaps, then the two facts that force it, then the Monday action for CRA strategist in a manufactured-housing lender with dealer-originated files.