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

Situation

After a DOJ or CFPB monitor request for pricing files, SPCP written plan versus actual originations is what HMDA data-quality manager can touch in a credit-card issuer changing line-assignment logic. Fair Lending will live with A special-purpose program is well designed versus A pretext on this Redlining and HMDA Data file.

Decision

HMDA data-quality manager in a credit-card issuer changing line-assignment logic must choose A special-purpose program is well designed / A pretext using SPCP written plan versus actual originations after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• SPCP written plan versus actual originations reads as A special-purpose program is well designed once a DOJ or CFPB monitor request for pricing files is lined up to the same Fair Lending population.
• SPCP written plan versus actual originations is closer to A pretext after a DOJ or CFPB monitor request for pricing files; A special-purpose program is well designed would over-claim this Redlining and HMDA Data extract.
• A dual reading is still live in SPCP written plan versus actual originations for HMDA data-quality manager in a credit-card issuer changing line-assignment logic.
• SPCP written plan versus actual originations is missing the fact HMDA data-quality manager needs after a DOJ or CFPB monitor request for pricing files; stop this Fair Lending close.

Analysis required

• Flag any disparate-impact table HMDA data-quality manager cannot explain from SPCP written plan versus actual originations.
• Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend.
• Match the adverse-action language to the facts in SPCP written plan versus actual originations.
• For this Fair Lending Redlining and HMDA Data file, read SPCP written plan versus actual originations against a DOJ or CFPB monitor request for pricing files and write the one fact that would move a special-purpose program is for HMDA data-quality manager.

Recommendation

Choose A special-purpose program is well designed / A pretext on this Fair Lending / Redlining and HMDA Data packet (SPCP written plan versus actual originations after a DOJ or CFPB monitor request for pricing files). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a DOJ or CFPB monitor request for pricing files, then the two facts that force it, then the Monday action for HMDA data-quality manager in a credit-card issuer changing line-assignment logic.