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

Situation

A mortgage company after a pricing-regression spike cannot treat a vendor score change with no disparate-impact test as color commentary on underwriting exception log by branch. CRA strategist must close a special-purpose program is from that extract under Fair Lending / CRA and Special-Purpose Programs.

Decision

CRA strategist in a mortgage company after a pricing-regression spike must choose A special-purpose program is well designed / A pretext using underwriting exception log by branch after a vendor score change with no disparate-impact test.

Hypotheses to test

• A vendor score change with no disparate-impact test is noise around an already-controlled CRA and Special-Purpose Programs process in a mortgage company after a pricing-regression spike, given underwriting exception log by branch.
• A vendor score change with no disparate-impact test is the event in underwriting exception log by branch that forces A special-purpose program is well designed for CRA strategist under Fair Lending.
• Underwriting exception log by branch shows a one-file miss after a vendor score change with no disparate-impact test, not a CRA and Special-Purpose Programs program failure.
• Underwriting exception log by branch cannot decide a special-purpose program is yet after a vendor score change with no disparate-impact test; hold is the only Fair Lending close a mortgage company after a pricing-regression spike can defend.

Analysis required

• Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend.
• Match the adverse-action language to the facts in underwriting exception log by branch.
• Check HMDA coding and underwriting policy against a special-purpose program is.
• For this Fair Lending CRA and Special-Purpose Programs file, read underwriting exception log by branch against a vendor score change with no disparate-impact test 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 / CRA and Special-Purpose Programs packet (underwriting exception log by branch after a vendor score change with no disparate-impact test). Lead with the Fair Lending option underwriting exception log by branch can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for CRA strategist in a mortgage company after a pricing-regression spike.