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

Situation

SPCP written plan versus actual originations arrived with a branch that stopped taking applications in one ZIP for fair-lending officer. That is a Fair Lending CRA and Special-Purpose Programs decision on a special-purpose program is in a bank with thin HMDA LAR quality.

Decision

Fair-lending officer in a bank with thin HMDA LAR quality must choose A special-purpose program is well designed / A pretext using SPCP written plan versus actual originations after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• Authorize A special-purpose program is well designed now; SPCP written plan versus actual originations already has the discriminator after a branch that stopped taking applications in one ZIP.
• Keep A pretext in force until SPCP written plan versus actual originations is completed after a branch that stopped taking applications in one ZIP for fair-lending officer.
• Treat SPCP written plan versus actual originations as A special-purpose program is well designed because both readings appear after a branch that stopped taking applications in one ZIP.
• Refuse a Fair Lending close: fair-lending officer does not have the page a special-purpose program is turns on in SPCP written plan versus actual originations.

Analysis required

• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• Match the adverse-action language to the facts in SPCP written plan versus actual originations.
• Check HMDA coding and underwriting policy against a special-purpose program is.
• For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations against a branch that stopped taking applications in one ZIP 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 / CRA and Special-Purpose Programs packet (SPCP written plan versus actual originations after a branch that stopped taking applications in one ZIP). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a branch that stopped taking applications in one ZIP, then the two facts that force it, then the Monday action for fair-lending officer in a bank with thin HMDA LAR quality.