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

Situation

In a manufactured-housing lender with dealer-originated files, model-reason-code mapping that does not match notices is the evidence after a notice that cites 'other' as the principal reason 40% of the time. Fair-lending officer has to pick A special-purpose program is well designed or A pretext for this Fair Lending Redlining and HMDA Data close using model-reason-code mapping that does not match notices.

Decision

Fair-lending officer in a manufactured-housing lender with dealer-originated files must choose A special-purpose program is well designed / A pretext using model-reason-code mapping that does not match notices after a notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• A notice that cites 'other' as the principal reason 40% of the time is noise around an already-controlled Redlining and HMDA Data process in a manufactured-housing lender with dealer-originated files, given model-reason-code mapping that does not match notices.
• A notice that cites 'other' as the principal reason 40% of the time is the event in model-reason-code mapping that does not match notices that forces A special-purpose program is well designed for fair-lending officer under Fair Lending.
• Model-reason-code mapping that does not match notices shows a one-file miss after a notice that cites 'other' as the principal reason 40% of the time, not a Redlining and HMDA Data program failure.
• Model-reason-code mapping that does not match notices cannot decide a special-purpose program is yet after a notice that cites 'other' as the principal reason 40% of the time; hold is the only Fair Lending close a manufactured-housing lender with dealer-originated files can defend.

Analysis required

• Match the adverse-action language to the facts in model-reason-code mapping that does not match notices.
• Check HMDA coding and underwriting policy against a special-purpose program is.
• Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time.
• For this Fair Lending Redlining and HMDA Data file, read model-reason-code mapping that does not match notices 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 fair-lending officer.