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

Situation

A special-purpose program is sits with second-review underwriter because a HMDA resubmission that still fails quality edits hit a lender expanding into majority-minority census tracts. Evidence is adverse-action notice principal-reason sample; write the Fair Lending CRA and Special-Purpose Programs option that extract can carry.

Decision

Second-review underwriter in a lender expanding into majority-minority census tracts must choose A special-purpose program is well designed / A pretext using adverse-action notice principal-reason sample after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• Second-review underwriter can defend A special-purpose program is well designed from adverse-action notice principal-reason sample after a HMDA resubmission that still fails quality edits in a Fair Lending challenge.
• Second-review underwriter cannot defend A special-purpose program is well designed from adverse-action notice principal-reason sample; A pretext is what the extract actually supports after a HMDA resubmission that still fails quality edits.
• A HMDA resubmission that still fails quality edits never reached the population in adverse-action notice principal-reason sample — reopen intake, do not close a special-purpose program is.
• Two facts in adverse-action notice principal-reason sample after a HMDA resubmission that still fails quality edits conflict for second-review underwriter; hold this CRA and Special-Purpose Programs file.

Analysis required

• Check HMDA coding and underwriting policy against a special-purpose program is.
• Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits.
• Flag any disparate-impact table second-review underwriter cannot explain from adverse-action notice principal-reason sample.
• For this Fair Lending CRA and Special-Purpose Programs file, read adverse-action notice principal-reason sample against a HMDA resubmission that still fails quality edits and write the one fact that would move a special-purpose program is for second-review underwriter.

Recommendation

Choose A special-purpose program is well designed / A pretext on this Fair Lending / CRA and Special-Purpose Programs packet (adverse-action notice principal-reason sample after a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option adverse-action notice principal-reason sample can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for second-review underwriter in a lender expanding into majority-minority census tracts.