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

Situation

A special-purpose program is sits with exam-response coordinator because a CRA PE that called the assessment area too narrow hit an institution preparing for a redlining exam. Evidence is CRA assessment-area versus lending footprint; write the Fair Lending Pricing and Credit Limits option that extract can carry.

Decision

Exam-response coordinator in an institution preparing for a redlining exam must choose A special-purpose program is well designed / A pretext using CRA assessment-area versus lending footprint after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• The population in CRA assessment-area versus lending footprint is the one a CRA PE that called the assessment area too narrow named, so A special-purpose program is well designed follows for this Pricing and Credit Limits file.
• The population in CRA assessment-area versus lending footprint is adjacent only to a CRA PE that called the assessment area too narrow; A pretext is the honest Fair Lending call.
• An institution preparing for a redlining exam already contained a CRA PE that called the assessment area too narrow before CRA assessment-area versus lending footprint arrived; no new Pricing and Credit Limits path.
• Provenance on CRA assessment-area versus lending footprint after a CRA PE that called the assessment area too narrow is broken; do not pick A special-purpose program is well designed or A pretext yet.

Analysis required

• Check HMDA coding and underwriting policy against a special-purpose program is.
• Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow.
• Flag any disparate-impact table exam-response coordinator cannot explain from CRA assessment-area versus lending footprint.
• For this Fair Lending Pricing and Credit Limits file, read CRA assessment-area versus lending footprint against a CRA PE that called the assessment area too narrow and write the one fact that would move a special-purpose program is for exam-response coordinator.

Recommendation

Choose A special-purpose program is well designed / A pretext on this Fair Lending / Pricing and Credit Limits packet (CRA assessment-area versus lending footprint after a CRA PE that called the assessment area too narrow). The follow-on Pricing and Credit Limits action is what exam-response coordinator does next: implement the option, assign an owner, and log the missing fact.