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

Situation

After an underwriter chat that used coded language, CRA assessment-area versus lending footprint is what adverse-action notice operations lead can touch in a lender expanding into majority-minority census tracts. Fair Lending will live with A special-purpose program is well designed versus A pretext on this Redlining and HMDA Data file.

Decision

Adverse-action notice operations lead in a lender expanding into majority-minority census tracts must choose A special-purpose program is well designed / A pretext using CRA assessment-area versus lending footprint after an underwriter chat that used coded language.

Hypotheses to test

• Authorize A special-purpose program is well designed now; CRA assessment-area versus lending footprint already has the discriminator after an underwriter chat that used coded language.
• Keep A pretext in force until CRA assessment-area versus lending footprint is completed after an underwriter chat that used coded language for adverse-action notice operations lead.
• Treat CRA assessment-area versus lending footprint as A special-purpose program is well designed because both readings appear after an underwriter chat that used coded language.
• Refuse a Fair Lending close: adverse-action notice operations lead does not have the page a special-purpose program is turns on in CRA assessment-area versus lending footprint.

Analysis required

• Match the adverse-action language to the facts in CRA assessment-area versus lending footprint.
• 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 an underwriter chat that used coded language.
• For this Fair Lending Redlining and HMDA Data file, read CRA assessment-area versus lending footprint against an underwriter chat that used coded language and write the one fact that would move a special-purpose program is for adverse-action notice operations lead.

Recommendation

Choose A special-purpose program is well designed / A pretext on this Fair Lending / Redlining and HMDA Data packet (CRA assessment-area versus lending footprint after an underwriter chat that used coded language). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after an underwriter chat that used coded language, then the two facts that force it, then the Monday action for adverse-action notice operations lead in a lender expanding into majority-minority census tracts.