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

SITUATION In a mortgage company after a pricing-regression spike, CRA assessment-area versus lending footprint is the evidence after a SPCP that originated almost no loans to the intended class. Fair-lending officer has to pick A special-purpose program is well designed or A pretext for this Fair Lending Pricing and Credit Limits close using CRA assessment-area versus lending footprint.

DECISION Fair-lending officer in a mortgage company after a pricing-regression spike must choose A special-purpose program is well designed / A pretext using CRA assessment-area versus lending footprint after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. CRA assessment-area versus lending footprint reads as A special-purpose program is well designed once a SPCP that originated almost no loans to the intended class is lined up to the same Fair Lending population. 2. CRA assessment-area versus lending footprint is closer to A pretext after a SPCP that originated almost no loans to the intended class; A special-purpose program is well designed would over-claim this Pricing and Credit Limits extract. 3. A dual reading is still live in CRA assessment-area versus lending footprint for fair-lending officer in a mortgage company after a pricing-regression spike. 4. CRA assessment-area versus lending footprint is missing the fact fair-lending officer needs after a SPCP that originated almost no loans to the intended class; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Flag any disparate-impact table fair-lending officer cannot explain from CRA assessment-area versus lending footprint. 2. Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend. 3. Match the adverse-action language to the facts in CRA assessment-area versus lending footprint. 4. For this Fair Lending Pricing and Credit Limits file, read CRA assessment-area versus lending footprint against a SPCP that originated almost no loans to the intended class and write the one fact that would move a special-purpose program is for fair-lending officer.

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 SPCP that originated almost no loans to the intended class). If CRA assessment-area versus lending footprint cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent missing evidence a mortgage company after a pricing-regression spike does not have.

COMMAND RETURNS - Bottom-line Fair Lending option on a special-purpose program is, then the evidence in CRA assessment-area versus lending footprint, then the action for fair-lending officer - Hypothesis scorecard against CRA assessment-area versus lending footprint: supported / rejected / untestable - Named option among A special-purpose program is well designed, A pretext and the fact that kills the others - Owner and next date for fair-lending officer in a mortgage company after a pricing-regression spike