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

Situation

A bank with thin HMDA LAR quality cannot treat a notice that cites 'other' as the principal reason 40% of the time as color commentary on geographic application and origination heat map. Exam-response coordinator must close a special-purpose program is from that extract under Fair Lending / Redlining and HMDA Data.

Decision

Exam-response coordinator in a bank with thin HMDA LAR quality must choose A special-purpose program is well designed / A pretext using geographic application and origination heat map after a notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• Authorize A special-purpose program is well designed now; geographic application and origination heat map already has the discriminator after a notice that cites 'other' as the principal reason 40% of the time.
• Keep A pretext in force until geographic application and origination heat map is completed after a notice that cites 'other' as the principal reason 40% of the time for exam-response coordinator.
• Treat geographic application and origination heat map as A special-purpose program is well designed because both readings appear after a notice that cites 'other' as the principal reason 40% of the time.
• Refuse a Fair Lending close: exam-response coordinator does not have the page a special-purpose program is turns on in geographic application and origination heat map.

Analysis required

• Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time.
• Flag any disparate-impact table exam-response coordinator cannot explain from geographic application and origination heat map.
• 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 geographic application and origination heat map against a notice that cites 'other' as the principal reason 40% of the time 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 (geographic application and origination heat map after a notice that cites 'other' as the principal reason 40% of the time). Lead with the Fair Lending option geographic application and origination heat map can support after a notice that cites 'other' as the principal reason 40% of the time, then the two facts that force it, then the Monday action for exam-response coordinator in a bank with thin HMDA LAR quality.