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

Situation

A special-purpose program is sits with CRA strategist because a vendor score change with no disparate-impact test hit an institution preparing for a redlining exam. Evidence is manufactured-housing dealer overlay notes; write the Fair Lending Redlining and HMDA Data option that extract can carry.

Decision

CRA strategist in an institution preparing for a redlining exam must choose A special-purpose program is well designed / A pretext using manufactured-housing dealer overlay notes after a vendor score change with no disparate-impact test.

Hypotheses to test

• The population in manufactured-housing dealer overlay notes is the one a vendor score change with no disparate-impact test named, so A special-purpose program is well designed follows for this Redlining and HMDA Data file.
• The population in manufactured-housing dealer overlay notes is adjacent only to a vendor score change with no disparate-impact test; A pretext is the honest Fair Lending call.
• An institution preparing for a redlining exam already contained a vendor score change with no disparate-impact test before manufactured-housing dealer overlay notes arrived; no new Redlining and HMDA Data path.
• Provenance on manufactured-housing dealer overlay notes after a vendor score change with no disparate-impact test is broken; do not pick A special-purpose program is well designed or A pretext yet.

Analysis required

• Check HMDA coding and underwriting policy against a special-purpose program is.
• Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test.
• Flag any disparate-impact table CRA strategist cannot explain from manufactured-housing dealer overlay notes.
• For this Fair Lending Redlining and HMDA Data file, read manufactured-housing dealer overlay notes against a vendor score change with no disparate-impact test and write the one fact that would move a special-purpose program is for CRA strategist.

Recommendation

Choose A special-purpose program is well designed / A pretext on this Fair Lending / Redlining and HMDA Data packet (manufactured-housing dealer overlay notes after a vendor score change with no disparate-impact test). The follow-on Redlining and HMDA Data action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.