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

Situation

After a board asking if the bank should settle a matched-pair study, CRA assessment-area versus lending footprint is what fair-lending officer can touch in a manufactured-housing lender with dealer-originated files. Fair Lending will live with A special-purpose program is well designed versus A pretext on this Redlining and HMDA Data file.

Decision

Fair-lending officer in a manufactured-housing lender with dealer-originated files must choose A special-purpose program is well designed / A pretext using CRA assessment-area versus lending footprint after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• Fair-lending officer can defend A special-purpose program is well designed from CRA assessment-area versus lending footprint after a board asking if the bank should settle a matched-pair study in a Fair Lending challenge.
• Fair-lending officer cannot defend A special-purpose program is well designed from CRA assessment-area versus lending footprint; A pretext is what the extract actually supports after a board asking if the bank should settle a matched-pair study.
• A board asking if the bank should settle a matched-pair study never reached the population in CRA assessment-area versus lending footprint — reopen intake, do not close a special-purpose program is.
• Two facts in CRA assessment-area versus lending footprint after a board asking if the bank should settle a matched-pair study conflict for fair-lending officer; hold this Redlining and HMDA Data file.

Analysis required

• Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study.
• Flag any disparate-impact table fair-lending officer cannot explain from CRA assessment-area versus lending footprint.
• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• For this Fair Lending Redlining and HMDA Data file, read CRA assessment-area versus lending footprint against a board asking if the bank should settle a matched-pair study and write the one fact that would move a special-purpose program is for fair-lending officer.

Recommendation