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

Situation

A special-purpose program is sits with community-development lender because a vendor score change with no disparate-impact test hit a mortgage company after a pricing-regression spike. Evidence is appraisal-gap outcomes in majority-minority tracts; write the Fair Lending Redlining and HMDA Data option that extract can carry.

Decision

Community-development lender in a mortgage company after a pricing-regression spike must choose A special-purpose program is well designed / A pretext using appraisal-gap outcomes in majority-minority tracts after a vendor score change with no disparate-impact test.

Hypotheses to test

• Appraisal-gap outcomes in majority-minority tracts reads as A special-purpose program is well designed once a vendor score change with no disparate-impact test is lined up to the same Fair Lending population.
• Appraisal-gap outcomes in majority-minority tracts is closer to A pretext after a vendor score change with no disparate-impact test; A special-purpose program is well designed would over-claim this Redlining and HMDA Data extract.
• A dual reading is still live in appraisal-gap outcomes in majority-minority tracts for community-development lender in a mortgage company after a pricing-regression spike.
• Appraisal-gap outcomes in majority-minority tracts is missing the fact community-development lender needs after a vendor score change with no disparate-impact test; stop this Fair Lending close.

Analysis required

• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts.
• Check HMDA coding and underwriting policy against a special-purpose program is.
• For this Fair Lending Redlining and HMDA Data file, read appraisal-gap outcomes in majority-minority tracts against a vendor score change with no disparate-impact test and write the one fact that would move a special-purpose program is for community-development lender.

Recommendation

Choose A special-purpose program is well designed / A pretext on this Fair Lending / Redlining and HMDA Data packet (appraisal-gap outcomes in majority-minority tracts after a vendor score change with no disparate-impact test). The follow-on Redlining and HMDA Data action is what community-development lender does next: implement the option, assign an owner, and log the missing fact.