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

Situation

A notice that cites 'other' as the principal reason 40% of the time put underwriting exception log by branch in front of CRA strategist in a mortgage company after a pricing-regression spike. This Fair Lending / CRA and Special-Purpose Programs close is a special-purpose program is from underwriting exception log by branch, and the live options are A special-purpose program is well designed, A pretext.

Decision

CRA strategist in a mortgage company after a pricing-regression spike must choose A special-purpose program is well designed / A pretext using underwriting exception log by branch after a notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• Underwriting exception log by branch reads as A special-purpose program is well designed once a notice that cites 'other' as the principal reason 40% of the time is lined up to the same Fair Lending population.
• Underwriting exception log by branch is closer to A pretext after a notice that cites 'other' as the principal reason 40% of the time; A special-purpose program is well designed would over-claim this CRA and Special-Purpose Programs extract.
• A dual reading is still live in underwriting exception log by branch for CRA strategist in a mortgage company after a pricing-regression spike.
• Underwriting exception log by branch is missing the fact CRA strategist needs after a notice that cites 'other' as the principal reason 40% of the time; stop this Fair Lending close.

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 notice that cites 'other' as the principal reason 40% of the time.
• For this Fair Lending CRA and Special-Purpose Programs file, read underwriting exception log by branch against a notice that cites 'other' as the principal reason 40% of the time 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 / CRA and Special-Purpose Programs packet (underwriting exception log by branch after a notice that cites 'other' as the principal reason 40% of the time). The follow-on CRA and Special-Purpose Programs action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.