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

SITUATION Exam-response coordinator owns this Pricing and Credit Limits review in an institution preparing for a redlining exam. An exception rate twice as high for one group after credit controls is the triggering event; underwriting exception log by branch is the evidence for whether a special-purpose program is well designed or a pretext.

DECISION Exam-response coordinator in an institution preparing for a redlining exam must choose A special-purpose program is well designed / A pretext using underwriting exception log by branch after an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. Authorize A special-purpose program is well designed now; underwriting exception log by branch already has the discriminator after an exception rate twice as high for one group after credit controls. 2. Keep A pretext in force until underwriting exception log by branch is completed after an exception rate twice as high for one group after credit controls for exam-response coordinator. 3. Treat underwriting exception log by branch as A special-purpose program is well designed because both readings appear after an exception rate twice as high for one group after credit controls. 4. Refuse a Fair Lending close: exam-response coordinator does not have the decision a special-purpose program is turns on in underwriting exception log by branch.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against a special-purpose program is. 2. Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls. 3. Flag any disparate-impact table exam-response coordinator cannot explain from underwriting exception log by branch. 4. For this Fair Lending Pricing and Credit Limits file, read underwriting exception log by branch against an exception rate twice as high for one group after credit controls and write the one fact that would move a special-purpose program is for exam-response coordinator.

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 an exception rate twice as high for one group after credit controls). Lead with the Fair Lending option underwriting exception log by branch can support after an exception rate twice as high for one group after credit controls, then the two facts that force it, then the Monday action for exam-response coordinator in an institution preparing for a redlining exam.

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 exam-response coordinator - Hypothesis scorecard against underwriting exception log by branch: supported / rejected / untestable - Regulatory or exam hook Pricing and Credit Limits would cite - Pricing and Credit Limits finding in underwriting exception log by branch that a second reviewer can re-perform