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

Situation

A vendor score change with no disparate-impact test put SPCP written plan versus actual originations in front of community-development lender in an institution preparing for a redlining exam. This Fair Lending / CRA and Special-Purpose Programs close is a special-purpose program is from SPCP written plan versus actual originations, and the live options are A special-purpose program is well designed, A pretext.

Decision

Community-development lender in an institution preparing for a redlining exam must choose A special-purpose program is well designed / A pretext using SPCP written plan versus actual originations after a vendor score change with no disparate-impact test.

Hypotheses to test

• Authorize A special-purpose program is well designed now; SPCP written plan versus actual originations already has the discriminator after a vendor score change with no disparate-impact test.
• Keep A pretext in force until SPCP written plan versus actual originations is completed after a vendor score change with no disparate-impact test for community-development lender.
• Treat SPCP written plan versus actual originations as A special-purpose program is well designed because both readings appear after a vendor score change with no disparate-impact test.
• Refuse a Fair Lending close: community-development lender does not have the page a special-purpose program is turns on in SPCP written plan versus actual originations.

Analysis required

• Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test.
• Flag any disparate-impact table community-development lender cannot explain from SPCP written plan versus actual originations.
• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations against a vendor score change with no disparate-impact test and write the one fact that would move a special-purpose program is for community-development lender.

Recommendation

Choose A special-purpose program is well designed / A pretext on this Fair Lending / CRA and Special-Purpose Programs packet (SPCP written plan versus actual originations after a vendor score change with no disparate-impact test). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for community-development lender in an institution preparing for a redlining exam.