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

Situation

Second-review underwriter owns a special-purpose program is inside a lender expanding into majority-minority census tracts with model-reason-code mapping that does not match notices as the only packet. A branch that stopped taking applications in one ZIP is what changed the clock for this Fair Lending CRA and Special-Purpose Programs file.

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 branch that stopped taking applications in one ZIP.

Hypotheses to test

• Model-reason-code mapping that does not match notices reads as A special-purpose program is well designed once a branch that stopped taking applications in one ZIP is lined up to the same Fair Lending population.
• Model-reason-code mapping that does not match notices is closer to A pretext after a branch that stopped taking applications in one ZIP; A special-purpose program is well designed would over-claim this CRA and Special-Purpose Programs extract.
• A dual reading is still live in model-reason-code mapping that does not match notices for second-review underwriter in a lender expanding into majority-minority census tracts.
• Model-reason-code mapping that does not match notices is missing the fact second-review underwriter needs after a branch that stopped taking applications in one ZIP; stop this Fair Lending close.

Analysis required

• Match the adverse-action language to the facts in model-reason-code mapping that does not match notices.
• 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 branch that stopped taking applications in one ZIP.
• For this Fair Lending CRA and Special-Purpose Programs file, read model-reason-code mapping that does not match notices against a branch that stopped taking applications in one ZIP 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 (model-reason-code mapping that does not match notices after a branch that stopped taking applications in one ZIP). The follow-on CRA and Special-Purpose Programs action is what second-review underwriter does next: implement the option, assign an owner, and log the missing fact.