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

Situation

After a HMDA resubmission that still fails quality edits, underwriting exception log by branch is what adverse-action notice operations lead can touch in a small-business desk using a new vendor score. Fair Lending will live with A special-purpose program is well designed versus A pretext on this CRA and Special-Purpose Programs file.

Decision

Adverse-action notice operations lead in a small-business desk using a new vendor score must choose A special-purpose program is well designed / A pretext using underwriting exception log by branch after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• The population in underwriting exception log by branch is the one a HMDA resubmission that still fails quality edits named, so A special-purpose program is well designed follows for this CRA and Special-Purpose Programs file.
• The population in underwriting exception log by branch is adjacent only to a HMDA resubmission that still fails quality edits; A pretext is the honest Fair Lending call.
• A small-business desk using a new vendor score already contained a HMDA resubmission that still fails quality edits before underwriting exception log by branch arrived; no new CRA and Special-Purpose Programs path.
• Provenance on underwriting exception log by branch after a HMDA resubmission that still fails quality edits is broken; do not pick A special-purpose program is well designed or A pretext yet.

Analysis required

• Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits.
• Flag any disparate-impact table adverse-action notice operations lead cannot explain from underwriting exception log by branch.
• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• For this Fair Lending CRA and Special-Purpose Programs file, read underwriting exception log by branch against a HMDA resubmission that still fails quality edits and write the one fact that would move a special-purpose program is for adverse-action notice operations lead.

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 HMDA resubmission that still fails quality edits). If underwriting exception log by branch cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If underwriting exception log by branch after a HMDA resubmission that still fails quality edits cannot support A special-purpose program is well designed versus A pretext on this Fair Lending CRA and Special-Purpose Programs close, adverse-action notice operations lead must do not infer a control or scheme beyond the transaction and entitlement evidence.