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

Situation

Model-reason-code mapping that does not match notices arrived with a marketing mailer that skipped majority-minority tracts for second-review underwriter. That is a Fair Lending CRA and Special-Purpose Programs decision on a special-purpose program is in a lender expanding into majority-minority census tracts.

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 model-reason-code mapping that does not match notices after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• A marketing mailer that skipped majority-minority tracts is noise around an already-controlled CRA and Special-Purpose Programs process in a lender expanding into majority-minority census tracts, given model-reason-code mapping that does not match notices.
• A marketing mailer that skipped majority-minority tracts is the event in model-reason-code mapping that does not match notices that forces A special-purpose program is well designed for second-review underwriter under Fair Lending.
• Model-reason-code mapping that does not match notices shows a one-file miss after a marketing mailer that skipped majority-minority tracts, not a CRA and Special-Purpose Programs program failure.
• Model-reason-code mapping that does not match notices cannot decide a special-purpose program is yet after a marketing mailer that skipped majority-minority tracts; hold is the only Fair Lending close a lender expanding into majority-minority census tracts can defend.

Analysis required

• Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts.
• Flag any disparate-impact table second-review underwriter cannot explain from model-reason-code mapping that does not match notices.
• Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend.
• For this Fair Lending CRA and Special-Purpose Programs file, read model-reason-code mapping that does not match notices against a marketing mailer that skipped majority-minority tracts and write the one fact that would move a special-purpose program is for second-review underwriter.