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

SITUATION After a board asking if the bank should settle a matched-pair study, underwriting exception log by branch is what community-development lender can touch in a bank with thin HMDA LAR quality. Fair Lending will live with A special-purpose program is well designed versus A pretext on this Pricing and Credit Limits file.

DECISION Community-development lender 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 board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. Underwriting exception log by branch reads as A special-purpose program is well designed once a board asking if the bank should settle a matched-pair study is lined up to the same Fair Lending population. 2. Underwriting exception log by branch is closer to A pretext after a board asking if the bank should settle a matched-pair study; A special-purpose program is well designed would over-claim this Pricing and Credit Limits extract. 3. A dual reading is still live in underwriting exception log by branch for community-development lender in a bank with thin HMDA LAR quality. 4. Underwriting exception log by branch is missing the fact community-development lender needs after a board asking if the bank should settle a matched-pair study; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Compare underwriting exception log by branch 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 underwriting exception log by branch. 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 underwriting exception log by branch 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 (underwriting exception log by branch 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 underwriting exception log by branch, then the action for community-development lender - Hypothesis scorecard against underwriting exception log by branch: supported / rejected / untestable - Owner and next date for community-development lender in a bank with thin HMDA LAR quality - What changes a special-purpose program is if a board asking if the bank should settle a matched-pair study is later withdrawn