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

Situation

CRA and Special-Purpose Programs work in a lender expanding into majority-minority census tracts now turns on a special-purpose program is because a notice that cites 'other' as the principal reason 40% of the time put mortgage pricing residual by prohibited-basis group in play. Second-review underwriter should say what mortgage pricing residual by prohibited-basis group proves.

Decision

Second-review underwriter in a lender expanding into majority-minority census tracts must choose A special-purpose program is well designed / A pretext using mortgage pricing residual by prohibited-basis group 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 CRA and Special-Purpose Programs process in a lender expanding into majority-minority census tracts, given mortgage pricing residual by prohibited-basis group.
• A notice that cites 'other' as the principal reason 40% of the time is the event in mortgage pricing residual by prohibited-basis group that forces A special-purpose program is well designed for second-review underwriter under Fair Lending.
• Mortgage pricing residual by prohibited-basis group shows a one-file miss after a notice that cites 'other' as the principal reason 40% of the time, not a CRA and Special-Purpose Programs program failure.
• Mortgage pricing residual by prohibited-basis group 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 lender expanding into majority-minority census tracts can defend.

Analysis required

• Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group.
• Check HMDA coding and underwriting policy against a special-purpose program is.
• Compare mortgage pricing residual by prohibited-basis group 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 CRA and Special-Purpose Programs file, read mortgage pricing residual by prohibited-basis group 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 second-review underwriter.