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

Situation

The Redlining and HMDA Data desk packet is SPCP written plan versus actual originations after a marketing mailer that skipped majority-minority tracts. CRA strategist in an institution preparing for a redlining exam must name A special-purpose program is well designed or A pretext for this Fair Lending file. CRA strategist in an institution preparing for a redlining exam has to name A special-purpose program is well designed or A pretext for this Fair Lending Redlining and HMDA Data file.

Decision

CRA strategist 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 marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• The population in SPCP written plan versus actual originations is the one a marketing mailer that skipped majority-minority tracts named, so A special-purpose program is well designed follows for this Redlining and HMDA Data file.
• The population in SPCP written plan versus actual originations is adjacent only to a marketing mailer that skipped majority-minority tracts; A pretext is the honest Fair Lending call.
• An institution preparing for a redlining exam already contained a marketing mailer that skipped majority-minority tracts before SPCP written plan versus actual originations arrived; no new Redlining and HMDA Data path.
• Provenance on SPCP written plan versus actual originations after a marketing mailer that skipped majority-minority tracts is broken; do not pick A special-purpose program is well designed or A pretext yet.

Analysis required

• Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts.
• Flag any disparate-impact table CRA strategist 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 Redlining and HMDA Data file, read SPCP written plan versus actual originations against a marketing mailer that skipped majority-minority tracts and write the one fact that would move a special-purpose program is for CRA strategist.

Recommendation