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

Situation

A special-purpose program is sits with second-review underwriter because a board asking if the bank should settle a matched-pair study hit a small-business desk using a new vendor score. Evidence is mortgage pricing residual by prohibited-basis group; write the Fair Lending Redlining and HMDA Data option that extract can carry.

Decision

Second-review underwriter in a small-business desk using a new vendor score must choose A special-purpose program is well designed / A pretext using mortgage pricing residual by prohibited-basis group after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• Mortgage pricing residual by prohibited-basis group reads as A special-purpose program is well designed once a board asking if the bank should settle a matched-pair study is lined up to the same Fair Lending population.
• Mortgage pricing residual by prohibited-basis group is closer to A pretext after a board asking if the bank should settle a matched-pair study; A special-purpose program is well designed would over-claim this Redlining and HMDA Data extract.
• A dual reading is still live in mortgage pricing residual by prohibited-basis group for second-review underwriter in a small-business desk using a new vendor score.
• Mortgage pricing residual by prohibited-basis group is missing the fact second-review underwriter needs after a board asking if the bank should settle a matched-pair study; stop this Fair Lending close.

Analysis required

• Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study.
• Flag any disparate-impact table second-review underwriter cannot explain from mortgage pricing residual by prohibited-basis group.
• Test a documented exception versus a pattern a small-business desk using a new vendor score must defend.
• For this Fair Lending Redlining and HMDA Data file, read mortgage pricing residual by prohibited-basis group against a board asking if the bank should settle a matched-pair study and write the one fact that would move a special-purpose program is for second-review underwriter.

Recommendation

Choose A special-purpose program is well designed / A pretext on this Fair Lending / Redlining and HMDA Data packet (mortgage pricing residual by prohibited-basis group after a board asking if the bank should settle a matched-pair study). The follow-on Redlining and HMDA Data action is what second-review underwriter does next: implement the option, assign an owner, and log the missing fact.