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

Situation

The desk packet is adverse-action notice principal-reason sample after a marketing mailer that skipped majority-minority tracts. Exam-response coordinator in a bank with thin HMDA LAR quality has to name A special-purpose program is well designed or A pretext for this Fair Lending Redlining and HMDA Data file.

Decision

Exam-response coordinator in a bank with thin HMDA LAR quality must choose A special-purpose program is well designed / A pretext using adverse-action notice principal-reason sample after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• A marketing mailer that skipped majority-minority tracts is noise around an already-controlled Redlining and HMDA Data process in a bank with thin HMDA LAR quality, given adverse-action notice principal-reason sample.
• A marketing mailer that skipped majority-minority tracts is the event in adverse-action notice principal-reason sample that forces A special-purpose program is well designed for exam-response coordinator under Fair Lending.
• Adverse-action notice principal-reason sample shows a one-file miss after a marketing mailer that skipped majority-minority tracts, not a Redlining and HMDA Data program failure.
• Adverse-action notice principal-reason sample cannot decide a special-purpose program is yet after a marketing mailer that skipped majority-minority tracts; hold is the only Fair Lending close a bank with thin HMDA LAR quality can defend.

Analysis required

• Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts.
• Flag any disparate-impact table exam-response coordinator cannot explain from adverse-action notice principal-reason sample.
• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• For this Fair Lending Redlining and HMDA Data file, read adverse-action notice principal-reason sample against a marketing mailer that skipped majority-minority tracts 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 / Redlining and HMDA Data packet (adverse-action notice principal-reason sample after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option adverse-action notice principal-reason sample can support after a marketing mailer that skipped majority-minority tracts, then the two facts that force it, then the Monday action for exam-response coordinator in a bank with thin HMDA LAR quality.