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

Situation

A vendor score change with no disparate-impact test put model-reason-code mapping that does not match notices in front of adverse-action notice operations lead in a lender expanding into majority-minority census tracts. This Fair Lending / Redlining and HMDA Data close is a special-purpose program is from model-reason-code mapping that does not match notices, and the live options are A special-purpose program is well designed, A pretext.

Decision

Adverse-action notice operations lead in a lender expanding into majority-minority census tracts must choose A special-purpose program is well designed / A pretext using model-reason-code mapping that does not match notices after a vendor score change with no disparate-impact test.

Hypotheses to test

• A vendor score change with no disparate-impact test is noise around an already-controlled Redlining and HMDA Data process in a lender expanding into majority-minority census tracts, given model-reason-code mapping that does not match notices.
• A vendor score change with no disparate-impact test is the event in model-reason-code mapping that does not match notices that forces A special-purpose program is well designed for adverse-action notice operations lead under Fair Lending.
• Model-reason-code mapping that does not match notices shows a one-file miss after a vendor score change with no disparate-impact test, 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 vendor score change with no disparate-impact test; hold is the only Fair Lending close a lender expanding into majority-minority census tracts can defend.

Analysis required

• 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 vendor score change with no disparate-impact test.
• Flag any disparate-impact table adverse-action notice operations lead cannot explain from model-reason-code mapping that does not match notices.
• For this Fair Lending Redlining and HMDA Data file, read model-reason-code mapping that does not match notices against a vendor score change with no disparate-impact test and write the one fact that would move a special-purpose program is for adverse-action notice operations lead.