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

Situation

Credit-card limit assignment disparity table arrived with a board asking if the bank should settle a matched-pair study 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 credit-card limit assignment disparity table after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• Second-review underwriter can defend A special-purpose program is well designed from credit-card limit assignment disparity table after a board asking if the bank should settle a matched-pair study in a Fair Lending challenge.
• Second-review underwriter cannot defend A special-purpose program is well designed from credit-card limit assignment disparity table; A pretext is what the extract actually supports after a board asking if the bank should settle a matched-pair study.
• A board asking if the bank should settle a matched-pair study never reached the population in credit-card limit assignment disparity table — reopen intake, do not close a special-purpose program is.
• Two facts in credit-card limit assignment disparity table after a board asking if the bank should settle a matched-pair study conflict for second-review underwriter; hold this CRA and Special-Purpose Programs file.

Analysis required

• Flag any disparate-impact table second-review underwriter cannot explain from credit-card limit assignment disparity table.
• Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend.
• Match the adverse-action language to the facts in credit-card limit assignment disparity table.
• For this Fair Lending CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table 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 / CRA and Special-Purpose Programs packet (credit-card limit assignment disparity table after a board asking if the bank should settle a matched-pair study). Lead with the Fair Lending option credit-card limit assignment disparity table can support after a board asking if the bank should settle a matched-pair study, then the two facts that force it, then the Monday action for second-review underwriter in a lender expanding into majority-minority census tracts.