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

Situation

Exam-response coordinator in a bank with thin HMDA LAR quality has one working extract — adverse-action notice principal-reason sample — after a SPCP that originated almost no loans to the intended class. If adverse-action notice principal-reason sample cannot support a special-purpose program is, the honest Fair Lending output is hold.

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 SPCP that originated almost no loans to the intended class.

Hypotheses to test

• Exam-response coordinator can defend A special-purpose program is well designed from adverse-action notice principal-reason sample after a SPCP that originated almost no loans to the intended class in a Fair Lending challenge.
• Exam-response coordinator cannot defend A special-purpose program is well designed from adverse-action notice principal-reason sample; A pretext is what the extract actually supports after a SPCP that originated almost no loans to the intended class.
• A SPCP that originated almost no loans to the intended class never reached the population in adverse-action notice principal-reason sample — reopen intake, do not close a special-purpose program is.
• Two facts in adverse-action notice principal-reason sample after a SPCP that originated almost no loans to the intended class conflict for exam-response coordinator; hold this Redlining and HMDA Data file.

Analysis required

• Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class.
• 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 SPCP that originated almost no loans to the intended class 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 SPCP that originated almost no loans to the intended class). Lead with the Fair Lending option adverse-action notice principal-reason sample can support after a SPCP that originated almost no loans to the intended class, then the two facts that force it, then the Monday action for exam-response coordinator in a bank with thin HMDA LAR quality.