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

Situation

After a CRA PE that called the assessment area too narrow, small-business decline comparative file set is what community-development lender can touch in a mortgage company after a pricing-regression spike. Fair Lending will live with A special-purpose program is well designed versus A pretext on this Redlining and HMDA Data file.

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 small-business decline comparative file set after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• The population in small-business decline comparative file set is the one a CRA PE that called the assessment area too narrow named, so A special-purpose program is well designed follows for this Redlining and HMDA Data file.
• The population in small-business decline comparative file set is adjacent only to a CRA PE that called the assessment area too narrow; A pretext is the honest Fair Lending call.
• A mortgage company after a pricing-regression spike already contained a CRA PE that called the assessment area too narrow before small-business decline comparative file set arrived; no new Redlining and HMDA Data path.
• Provenance on small-business decline comparative file set after a CRA PE that called the assessment area too narrow is broken; do not pick A special-purpose program is well designed or A pretext yet.

Analysis required

• Match the adverse-action language to the facts in small-business decline comparative file set.
• Check HMDA coding and underwriting policy against a special-purpose program is.
• Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow.
• For this Fair Lending Redlining and HMDA Data file, read small-business decline comparative file set against a CRA PE that called the assessment area too narrow 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 (small-business decline comparative file set after a CRA PE that called the assessment area too narrow). 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.