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

Situation

A special-purpose program is sits with CRA strategist because a marketing mailer that skipped majority-minority tracts hit a bank with thin HMDA LAR quality. Evidence is HMDA LAR validity and quality edits; 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 HMDA LAR validity and quality edits after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• The population in HMDA LAR validity and quality edits is the one a marketing mailer that skipped majority-minority tracts named, so A special-purpose program is well designed follows for this Examination and Notices file.
• The population in HMDA LAR validity and quality edits is adjacent only to a marketing mailer that skipped majority-minority tracts; A pretext is the honest Fair Lending call.
• A bank with thin HMDA LAR quality already contained a marketing mailer that skipped majority-minority tracts before HMDA LAR validity and quality edits arrived; no new Examination and Notices path.
• Provenance on HMDA LAR validity and quality edits after a marketing mailer that skipped majority-minority tracts is broken; do not pick A special-purpose program is well designed or A pretext yet.

Analysis required

• Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts.
• Flag any disparate-impact table CRA strategist cannot explain from HMDA LAR validity and quality edits.
• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• For this Fair Lending Examination and Notices file, read HMDA LAR validity and quality edits against a marketing mailer that skipped majority-minority tracts 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 (HMDA LAR validity and quality edits after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option HMDA LAR validity and quality edits can support after a marketing mailer that skipped majority-minority tracts, then the two facts that force it, then the Monday action for CRA strategist in a bank with thin HMDA LAR quality.