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

Situation

After a branch that stopped taking applications in one ZIP, small-business decline comparative file set is what CRA strategist can touch in a bank with thin HMDA LAR quality. Fair Lending will live with A special-purpose program is well designed versus A pretext on this Examination and Notices file.

Decision

CRA strategist in a bank with thin HMDA LAR quality must choose A special-purpose program is well designed / A pretext using small-business decline comparative file set after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• CRA strategist can defend A special-purpose program is well designed from small-business decline comparative file set after a branch that stopped taking applications in one ZIP in a Fair Lending challenge.
• CRA strategist cannot defend A special-purpose program is well designed from small-business decline comparative file set; A pretext is what the extract actually supports after a branch that stopped taking applications in one ZIP.
• A branch that stopped taking applications in one ZIP never reached the population in small-business decline comparative file set — reopen intake, do not close a special-purpose program is.
• Two facts in small-business decline comparative file set after a branch that stopped taking applications in one ZIP conflict for CRA strategist; hold this Examination and Notices file.

Analysis required

• Flag any disparate-impact table CRA strategist cannot explain from small-business decline comparative file set.
• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• Match the adverse-action language to the facts in small-business decline comparative file set.
• For this Fair Lending Examination and Notices file, read small-business decline comparative file set against a branch that stopped taking applications in one ZIP and write the one fact that would move a special-purpose program is for CRA strategist.

Recommendation

Choose A special-purpose program is well designed / A pretext on this Fair Lending / Examination and Notices packet (small-business decline comparative file set after a branch that stopped taking applications in one ZIP). If small-business decline comparative file set cannot force a Fair Lending label under Examination and Notices, stop. If small-business decline comparative file set after a branch that stopped taking applications in one ZIP cannot support A special-purpose program is well designed versus A pretext on this Fair Lending Examination and Notices close, CRA strategist must do not infer a control or scheme beyond the transaction and entitlement evidence.