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

Situation

Fair-lending officer owns a special-purpose program is inside an institution preparing for a redlining exam with SPCP written plan versus actual originations as the only packet. A CRA PE that called the assessment area too narrow is what changed the clock for this Fair Lending Examination and Notices file.

Decision

Fair-lending officer in an institution preparing for a redlining exam must choose A special-purpose program is well designed / A pretext using SPCP written plan versus actual originations after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• A CRA PE that called the assessment area too narrow is noise around an already-controlled Examination and Notices process in an institution preparing for a redlining exam, given SPCP written plan versus actual originations.
• A CRA PE that called the assessment area too narrow is the event in SPCP written plan versus actual originations that forces A special-purpose program is well designed for fair-lending officer under Fair Lending.
• SPCP written plan versus actual originations shows a one-file miss after a CRA PE that called the assessment area too narrow, not a Examination and Notices program failure.
• SPCP written plan versus actual originations cannot decide a special-purpose program is yet after a CRA PE that called the assessment area too narrow; hold is the only Fair Lending close an institution preparing for a redlining exam can defend.

Analysis required

• Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow.
• Flag any disparate-impact table fair-lending officer cannot explain from SPCP written plan versus actual originations.
• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• For this Fair Lending Examination and Notices file, read SPCP written plan versus actual originations against a CRA PE that called the assessment area too narrow and write the one fact that would move a special-purpose program is for fair-lending officer.

Recommendation

Choose A special-purpose program is well designed / A pretext on this Fair Lending / Examination and Notices packet (SPCP written plan versus actual originations after a CRA PE that called the assessment area too narrow). The follow-on Examination and Notices action is what fair-lending officer does next: implement the option, assign an owner, and log the missing fact.