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

Situation

After a HMDA resubmission that still fails quality edits, credit-card limit assignment disparity table 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 credit-card limit assignment disparity table after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• Authorize A special-purpose program is well designed now; credit-card limit assignment disparity table already has the discriminator after a HMDA resubmission that still fails quality edits.
• Keep A pretext in force until credit-card limit assignment disparity table is completed after a HMDA resubmission that still fails quality edits for adverse-action notice operations lead.
• Treat credit-card limit assignment disparity table as A special-purpose program is well designed because both readings appear after a HMDA resubmission that still fails quality edits.
• Refuse a Fair Lending close: adverse-action notice operations lead does not have the page a special-purpose program is turns on in credit-card limit assignment disparity table.

Analysis required

• Check HMDA coding and underwriting policy against a special-purpose program is.
• Compare credit-card limit assignment disparity table 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 credit-card limit assignment disparity table.
• For this Fair Lending CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table 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 (credit-card limit assignment disparity table after a HMDA resubmission that still fails quality edits). The follow-on CRA and Special-Purpose Programs action is what adverse-action notice operations lead does next: implement the option, assign an owner, and log the missing fact.