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

Situation

A vendor score change with no disparate-impact test put HMDA LAR validity and quality edits in front of second-review underwriter in a lender expanding into majority-minority census tracts. This Fair Lending / CRA and Special-Purpose Programs close is a special-purpose program is from HMDA LAR validity and quality edits, and the live options are A special-purpose program is well designed, A pretext.

Decision

Second-review underwriter in a lender expanding into majority-minority census tracts must choose A special-purpose program is well designed / A pretext using HMDA LAR validity and quality edits after a vendor score change with no disparate-impact test.

Hypotheses to test

• The population in HMDA LAR validity and quality edits is the one a vendor score change with no disparate-impact test named, so A special-purpose program is well designed follows for this CRA and Special-Purpose Programs file.
• The population in HMDA LAR validity and quality edits is adjacent only to a vendor score change with no disparate-impact test; A pretext is the honest Fair Lending call.
• A lender expanding into majority-minority census tracts already contained a vendor score change with no disparate-impact test before HMDA LAR validity and quality edits arrived; no new CRA and Special-Purpose Programs path.
• Provenance on HMDA LAR validity and quality edits after a vendor score change with no disparate-impact test is broken; do not pick A special-purpose program is well designed or A pretext yet.

Analysis required

• Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend.
• Match the adverse-action language to the facts in HMDA LAR validity and quality edits.
• Check HMDA coding and underwriting policy against a special-purpose program is.
• For this Fair Lending CRA and Special-Purpose Programs file, read HMDA LAR validity and quality edits against a vendor score change with no disparate-impact test and write the one fact that would move a special-purpose program is for second-review underwriter.

Recommendation

Choose A special-purpose program is well designed / A pretext on this Fair Lending / CRA and Special-Purpose Programs packet (HMDA LAR validity and quality edits after a vendor score change with no disparate-impact test). The follow-on CRA and Special-Purpose Programs action is what second-review underwriter does next: implement the option, assign an owner, and log the missing fact.