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

SITUATION A vendor score change with no disparate-impact test put small-business decline comparative file set in front of community-development lender in a bank with thin HMDA LAR quality. This Fair Lending / Pricing and Credit Limits decision is a special-purpose program is from small-business decline comparative file set, and the live options are A special-purpose program is well designed, A pretext.

DECISION Community-development lender in a bank with thin HMDA LAR quality must choose A special-purpose program is well designed / A pretext using small-business decline comparative file set after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. Small-business decline comparative file set reads as A special-purpose program is well designed once a vendor score change with no disparate-impact test is lined up to the same Fair Lending population. 2. Small-business decline comparative file set is closer to A pretext after a vendor score change with no disparate-impact test; A special-purpose program is well designed would over-claim this Pricing and Credit Limits extract. 3. A dual reading is still live in small-business decline comparative file set for community-development lender in a bank with thin HMDA LAR quality. 4. Small-business decline comparative file set is missing the fact community-development lender needs after a vendor score change with no disparate-impact test; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test. 2. Flag any disparate-impact table community-development lender cannot explain from small-business decline comparative file set. 3. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 4. For this Fair Lending Pricing and Credit Limits file, read small-business decline comparative file set against a vendor score change with no disparate-impact test 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 / Pricing and Credit Limits packet (small-business decline comparative file set after a vendor score change with no disparate-impact test). Lead with the Fair Lending option small-business decline comparative file set can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for community-development lender in a bank with thin HMDA LAR quality.

COMMAND RETURNS - Bottom-line Fair Lending option on a special-purpose program is, then the evidence in small-business decline comparative file set, then the action for community-development lender - Hypothesis scorecard against small-business decline comparative file set: supported / rejected / untestable - What changes a special-purpose program is if a vendor score change with no disparate-impact test is later withdrawn - Named option among A special-purpose program is well designed, A pretext and the fact that kills the others