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

Situation

A special-purpose program is sits with CRA strategist because a notice that cites 'other' as the principal reason 40% of the time hit a bank with thin HMDA LAR quality. Evidence is CRA assessment-area versus lending footprint; write the Fair Lending Examination and Notices option that extract can carry.

Decision

CRA strategist in a bank with thin HMDA LAR quality must choose A special-purpose program is well designed / A pretext using CRA assessment-area versus lending footprint after a notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• A notice that cites 'other' as the principal reason 40% of the time is noise around an already-controlled Examination and Notices process in a bank with thin HMDA LAR quality, given CRA assessment-area versus lending footprint.
• A notice that cites 'other' as the principal reason 40% of the time is the event in CRA assessment-area versus lending footprint that forces A special-purpose program is well designed for CRA strategist under Fair Lending.
• CRA assessment-area versus lending footprint shows a one-file miss after a notice that cites 'other' as the principal reason 40% of the time, not a Examination and Notices program failure.
• CRA assessment-area versus lending footprint cannot decide a special-purpose program is yet after a notice that cites 'other' as the principal reason 40% of the time; hold is the only Fair Lending close a bank with thin HMDA LAR quality can defend.

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 a notice that cites 'other' as the principal reason 40% of the time.
• For this Fair Lending Examination and Notices file, read CRA assessment-area versus lending footprint against a notice that cites 'other' as the principal reason 40% of the time 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 (CRA assessment-area versus lending footprint after a notice that cites 'other' as the principal reason 40% of the time). The follow-on Examination and Notices action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.