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

Situation

After a branch that stopped taking applications in one ZIP, underwriting exception log by branch is what CRA strategist can touch in a manufactured-housing lender with dealer-originated files. Fair Lending will live with A special-purpose program is well designed versus A pretext on this Pricing and Credit Limits file.

Decision

CRA strategist in a manufactured-housing lender with dealer-originated files must choose A special-purpose program is well designed / A pretext using underwriting exception log by branch after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• Authorize A special-purpose program is well designed now; underwriting exception log by branch already has the discriminator after a branch that stopped taking applications in one ZIP.
• Keep A pretext in force until underwriting exception log by branch is completed after a branch that stopped taking applications in one ZIP for CRA strategist.
• Treat underwriting exception log by branch as A special-purpose program is well designed because both readings appear after a branch that stopped taking applications in one ZIP.
• Refuse a Fair Lending close: CRA strategist does not have the page a special-purpose program is turns on in underwriting exception log by branch.

Analysis required

• Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP.
• Flag any disparate-impact table CRA strategist cannot explain from underwriting exception log by branch.
• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• For this Fair Lending Pricing and Credit Limits file, read underwriting exception log by branch against a branch that stopped taking applications in one ZIP 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 (underwriting exception log by branch after a branch that stopped taking applications in one ZIP). Lead with the Fair Lending option underwriting exception log by branch can support after a branch that stopped taking applications in one ZIP, then the two facts that force it, then the Monday action for CRA strategist in a manufactured-housing lender with dealer-originated files.