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

Situation

Community-development lender owns a special-purpose program is inside a manufactured-housing lender with dealer-originated files with HMDA LAR validity and quality edits as the only packet. A SPCP that originated almost no loans to the intended class is what changed the clock for this Fair Lending Examination and Notices file.

Decision

Community-development lender in a manufactured-housing lender with dealer-originated files must choose A special-purpose program is well designed / A pretext using HMDA LAR validity and quality edits after a SPCP that originated almost no loans to the intended class.

Hypotheses to test

• Authorize A special-purpose program is well designed now; HMDA LAR validity and quality edits already has the discriminator after a SPCP that originated almost no loans to the intended class.
• Keep A pretext in force until HMDA LAR validity and quality edits is completed after a SPCP that originated almost no loans to the intended class for community-development lender.
• Treat HMDA LAR validity and quality edits as A special-purpose program is well designed because both readings appear after a SPCP that originated almost no loans to the intended class.
• Refuse a Fair Lending close: community-development lender does not have the page a special-purpose program is turns on in HMDA LAR validity and quality edits.

Analysis required

• 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.
• Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class.
• For this Fair Lending Examination and Notices file, read HMDA LAR validity and quality edits against a SPCP that originated almost no loans to the intended class 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 / Examination and Notices packet (HMDA LAR validity and quality edits after a SPCP that originated almost no loans to the intended class). The follow-on Examination and Notices action is what community-development lender does next: implement the option, assign an owner, and log the missing fact.