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

SITUATION The working file is CRA assessment-area versus lending footprint after a community complaint about appraisal gaps. Community-development lender in a bank with thin HMDA LAR quality has to name A special-purpose program is well designed or A pretext for this Fair Lending Pricing and Credit Limits file.

DECISION Community-development lender 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 community complaint about appraisal gaps.

HYPOTHESES TO TEST 1. CRA assessment-area versus lending footprint reads as A special-purpose program is well designed once a community complaint about appraisal gaps is lined up to the same Fair Lending population. 2. CRA assessment-area versus lending footprint is closer to A pretext after a community complaint about appraisal gaps; 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 community-development lender in a bank with thin HMDA LAR quality. 4. CRA assessment-area versus lending footprint is missing the fact community-development lender needs after a community complaint about appraisal gaps; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Flag any disparate-impact table community-development lender cannot explain from CRA assessment-area versus lending footprint. 2. Test a documented exception versus a pattern a bank with thin HMDA LAR quality 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 community complaint about appraisal gaps and write the one fact that would move a special-purpose program is for community-development lender.

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 community complaint about appraisal gaps). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after a community complaint about appraisal gaps, then the two facts that force it, then the Monday action for community-development lender in a bank with thin HMDA LAR quality.

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 community-development lender - 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 community-development lender in a bank with thin HMDA LAR quality