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

Situation

CRA and Special-Purpose Programs work in a lender expanding into majority-minority census tracts now turns on a special-purpose program is because a vendor score change with no disparate-impact test put credit-card limit assignment disparity table in play. CRA and Special-Purpose Programs work in a lender expanding into majority-minority census tracts now turns on a special-purpose program is because a vendor score change with no disparate-impact test put credit-card limit assignment disparity table in play; second-review underwriter should say what credit-card limit assignment disparity table proves for Fair Lending.

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 credit-card limit assignment disparity table after a vendor score change with no disparate-impact test.

Hypotheses to test

• Authorize A special-purpose program is well designed now; credit-card limit assignment disparity table already has the discriminator after a vendor score change with no disparate-impact test.
• Keep A pretext in force until credit-card limit assignment disparity table is completed after a vendor score change with no disparate-impact test for second-review underwriter.
• Treat credit-card limit assignment disparity table as A special-purpose program is well designed because both readings appear after a vendor score change with no disparate-impact test.
• Refuse a Fair Lending close: second-review underwriter does not have the page a special-purpose program is turns on in credit-card limit assignment disparity table.

Analysis required

• Flag any disparate-impact table second-review underwriter cannot explain from credit-card limit assignment disparity table.
• Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend.
• Match the adverse-action language to the facts in 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 vendor score change with no disparate-impact test and write the one fact that would move a special-purpose program is for second-review underwriter.

Recommendation