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

Situation

After a CRA PE that called the assessment area too narrow, underwriting exception log by branch is what CRA strategist can touch in an institution preparing for a redlining exam. Fair Lending will live with A special-purpose program is well designed versus A pretext on this Redlining and HMDA Data file.

Decision

CRA strategist in an institution preparing for a redlining exam must choose A special-purpose program is well designed / A pretext using underwriting exception log by branch after a CRA PE that called the assessment area too narrow.

Hypotheses to test

• Authorize A special-purpose program is well designed now; underwriting exception log by branch already has the discriminator after a CRA PE that called the assessment area too narrow.
• Keep A pretext in force until underwriting exception log by branch is completed after a CRA PE that called the assessment area too narrow for CRA strategist.
• Treat underwriting exception log by branch as A special-purpose program is well designed because both readings appear after a CRA PE that called the assessment area too narrow.
• Refuse a Fair Lending close: CRA strategist does not have the page a special-purpose program is turns on in underwriting exception log by branch.

Analysis required

• Compare underwriting exception log by branch 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 CRA strategist cannot explain from underwriting exception log by branch.
• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• For this Fair Lending Redlining and HMDA Data file, read underwriting exception log by branch 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 CRA strategist.

Recommendation

Choose A special-purpose program is well designed / A pretext on this Fair Lending / Redlining and HMDA Data packet (underwriting exception log by branch after a CRA PE that called the assessment area too narrow). The follow-on Redlining and HMDA Data action is what CRA strategist does next: implement the option, assign an owner, and log the missing fact.