Whether a special-purpose program is well designed or a pretext from HMDA LAR

Situation

After a CRA PE that called the assessment area too narrow, HMDA LAR validity and quality edits is what fair-lending officer can touch in a mortgage company after a pricing-regression spike. Fair Lending will live with A special-purpose program is well designed versus A pretext on this Pricing and Credit Limits file.

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 HMDA LAR validity and quality edits after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• Authorize A special-purpose program is well designed now; HMDA LAR validity and quality edits already has the discriminator after a CRA PE that called the assessment area too narrow.
• Keep A pretext in force until HMDA LAR validity and quality edits is completed after a CRA PE that called the assessment area too narrow for fair-lending officer.
• Treat HMDA LAR validity and quality edits as A special-purpose program is well designed because both readings appear after a CRA PE that called the assessment area too narrow.
• Refuse a Fair Lending close: fair-lending officer does not have the page a special-purpose program is turns on in HMDA LAR validity and quality edits.

Analysis required

• Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow.
• Flag any disparate-impact table fair-lending officer cannot explain from HMDA LAR validity and quality edits.
• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• For this Fair Lending Pricing and Credit Limits file, read HMDA LAR validity and quality edits against a CRA PE that called the assessment area too narrow 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 (HMDA LAR validity and quality edits after a CRA PE that called the assessment area too narrow). If HMDA LAR validity and quality edits cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent pages a mortgage company after a pricing-regression spike does not have.