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

Situation

SPCP written plan versus actual originations arrived with a SPCP that originated almost no loans to the intended class 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 SPCP that originated almost no loans to the intended class.

Hypotheses to test

• SPCP written plan versus actual originations reads as A special-purpose program is well designed once a SPCP that originated almost no loans to the intended class is lined up to the same Fair Lending population.
• SPCP written plan versus actual originations is closer to A pretext after a SPCP that originated almost no loans to the intended class; A special-purpose program is well designed would over-claim this CRA and Special-Purpose Programs extract.
• A dual reading is still live in SPCP written plan versus actual originations for fair-lending officer in a bank with thin HMDA LAR quality.
• SPCP written plan versus actual originations is missing the fact fair-lending officer needs after a SPCP that originated almost no loans to the intended class; stop this Fair Lending close.

Analysis required

• 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.
• Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class.
• For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations against a SPCP that originated almost no loans to the intended class 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 SPCP that originated almost no loans to the intended class). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a SPCP that originated almost no loans to the intended class, then the two facts that force it, then the Monday action for fair-lending officer in a bank with thin HMDA LAR quality.