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

Situation

The desk packet is HMDA LAR validity and quality edits after a board asking if the bank should settle a matched-pair study. Community-development lender in a manufactured-housing lender with dealer-originated files has to name A special-purpose program is well designed or A pretext 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 board asking if the bank should settle a matched-pair study.

Hypotheses to test

• A board asking if the bank should settle a matched-pair study is noise around an already-controlled Examination and Notices process in a manufactured-housing lender with dealer-originated files, given HMDA LAR validity and quality edits.
• A board asking if the bank should settle a matched-pair study is the event in HMDA LAR validity and quality edits that forces A special-purpose program is well designed for community-development lender under Fair Lending.
• HMDA LAR validity and quality edits shows a one-file miss after a board asking if the bank should settle a matched-pair study, not a Examination and Notices program failure.
• HMDA LAR validity and quality edits cannot decide a special-purpose program is yet after a board asking if the bank should settle a matched-pair study; hold is the only Fair Lending close a manufactured-housing lender with dealer-originated files can defend.

Analysis required

• 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 board asking if the bank should settle a matched-pair study.
• Flag any disparate-impact table community-development lender cannot explain from HMDA LAR validity and quality edits.
• For this Fair Lending Examination and Notices file, read HMDA LAR validity and quality edits against a board asking if the bank should settle a matched-pair study 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 board asking if the bank should settle a matched-pair study). If HMDA LAR validity and quality edits cannot force a Fair Lending label under Examination and Notices, stop. Do not invent pages a manufactured-housing lender with dealer-originated files does not have.