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

Situation

The desk packet is underwriting exception log by branch after a SPCP that originated almost no loans to the intended class. Fair-lending officer in a bank with thin HMDA LAR quality has to name A special-purpose program is well designed or A pretext for this Fair Lending CRA and Special-Purpose Programs file.

Decision

Fair-lending officer in a bank with thin HMDA LAR quality must choose A special-purpose program is well designed / A pretext using underwriting exception log by branch after a SPCP that originated almost no loans to the intended class.

Hypotheses to test

• A SPCP that originated almost no loans to the intended class is noise around an already-controlled CRA and Special-Purpose Programs process in a bank with thin HMDA LAR quality, given underwriting exception log by branch.
• A SPCP that originated almost no loans to the intended class is the event in underwriting exception log by branch that forces A special-purpose program is well designed for fair-lending officer under Fair Lending.
• Underwriting exception log by branch shows a one-file miss after a SPCP that originated almost no loans to the intended class, not a CRA and Special-Purpose Programs program failure.
• Underwriting exception log by branch cannot decide a special-purpose program is yet after a SPCP that originated almost no loans to the intended class; hold is the only Fair Lending close a bank with thin HMDA LAR quality can defend.

Analysis required

• Match the adverse-action language to the facts in underwriting exception log by branch.
• Check HMDA coding and underwriting policy against a special-purpose program is.
• Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class.
• For this Fair Lending CRA and Special-Purpose Programs file, read underwriting exception log by branch against a SPCP that originated almost no loans to the intended class and write the one fact that would move a special-purpose program is for fair-lending officer.

Recommendation

Choose A special-purpose program is well designed / A pretext on this Fair Lending / CRA and Special-Purpose Programs packet (underwriting exception log by branch after a SPCP that originated almost no loans to the intended class). Lead with the Fair Lending option underwriting exception log by branch can support after a SPCP that originated almost no loans to the intended class, then the two facts that force it, then the Monday action for fair-lending officer in a bank with thin HMDA LAR quality.