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

SITUATION A bank with thin HMDA LAR quality cannot treat a board asking if the bank should settle a matched-pair study as incidental context on SPCP written plan versus actual originations. Community-development lender must close a special-purpose program is from that extract under Fair Lending / Pricing and Credit Limits.

DECISION Community-development lender in a bank with thin HMDA LAR quality must choose A special-purpose program is well designed / A pretext using SPCP written plan versus actual originations after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. Community-development lender can defend A special-purpose program is well designed from SPCP written plan versus actual originations after a board asking if the bank should settle a matched-pair study in a Fair Lending challenge. 2. Community-development lender cannot defend A special-purpose program is well designed from SPCP written plan versus actual originations; A pretext is what the extract actually supports after a board asking if the bank should settle a matched-pair study. 3. A board asking if the bank should settle a matched-pair study never reached the population in SPCP written plan versus actual originations — reopen intake, do not close a special-purpose program is. 4. Two facts in SPCP written plan versus actual originations after a board asking if the bank should settle a matched-pair study conflict for community-development lender; hold this Pricing and Credit Limits file.

ANALYSIS REQUIRED 1. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study. 2. Flag any disparate-impact table community-development lender cannot explain from SPCP written plan versus actual originations. 3. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 4. For this Fair Lending Pricing and Credit Limits file, read SPCP written plan versus actual originations against a board asking if the bank should settle a matched-pair study 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 / Pricing and Credit Limits packet (SPCP written plan versus actual originations after a board asking if the bank should settle a matched-pair study). The follow-on Pricing and Credit Limits action is what community-development lender does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on a special-purpose program is, then the evidence in SPCP written plan versus actual originations, then the action for community-development lender - Hypothesis scorecard against SPCP written plan versus actual originations: supported / rejected / untestable - What changes a special-purpose program is if a board asking if the bank should settle a matched-pair study is later withdrawn - Named option among A special-purpose program is well designed, A pretext and the fact that kills the others