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

Situation

A special-purpose program is sits with community-development lender because a HMDA resubmission that still fails quality edits hit an institution preparing for a redlining exam. Evidence is SPCP written plan versus actual originations; write the Fair Lending CRA and Special-Purpose Programs option that extract can carry.

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 HMDA resubmission that still fails quality edits.

Hypotheses to test

• The population in SPCP written plan versus actual originations is the one a HMDA resubmission that still fails quality edits named, so A special-purpose program is well designed follows for this CRA and Special-Purpose Programs file.
• The population in SPCP written plan versus actual originations is adjacent only to a HMDA resubmission that still fails quality edits; A pretext is the honest Fair Lending call.
• An institution preparing for a redlining exam already contained a HMDA resubmission that still fails quality edits before SPCP written plan versus actual originations arrived; no new CRA and Special-Purpose Programs path.
• Provenance on SPCP written plan versus actual originations after a HMDA resubmission that still fails quality edits is broken; do not pick A special-purpose program is well designed or A pretext yet.

Analysis required

• 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.
• Match the adverse-action language to the facts in SPCP written plan versus actual originations.
• For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations against a HMDA resubmission that still fails quality edits 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 HMDA resubmission that still fails quality edits). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for community-development lender in an institution preparing for a redlining exam.