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

Situation

A special-purpose program is sits with fair-lending officer because a board asking if the bank should settle a matched-pair study hit a bank with thin HMDA LAR quality. Evidence is geographic application and origination heat map; write the Fair Lending CRA and Special-Purpose Programs option that extract can carry.

Decision

Fair-lending officer in a bank with thin HMDA LAR quality must choose A special-purpose program is well designed / A pretext using geographic application and origination heat map after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• The population in geographic application and origination heat map is the one a board asking if the bank should settle a matched-pair study named, so A special-purpose program is well designed follows for this CRA and Special-Purpose Programs file.
• The population in geographic application and origination heat map is adjacent only to a board asking if the bank should settle a matched-pair study; A pretext is the honest Fair Lending call.
• A bank with thin HMDA LAR quality already contained a board asking if the bank should settle a matched-pair study before geographic application and origination heat map arrived; no new CRA and Special-Purpose Programs path.
• Provenance on geographic application and origination heat map after a board asking if the bank should settle a matched-pair study is broken; do not pick A special-purpose program is well designed or A pretext yet.

Analysis required

• Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study.
• Flag any disparate-impact table fair-lending officer cannot explain from geographic application and origination heat map.
• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• For this Fair Lending CRA and Special-Purpose Programs file, read geographic application and origination heat map against a board asking if the bank should settle a matched-pair study 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 (geographic application and origination heat map after a board asking if the bank should settle a matched-pair study). Lead with the Fair Lending option geographic application and origination heat map can support after a board asking if the bank should settle a matched-pair study, then the two facts that force it, then the Monday action for fair-lending officer in a bank with thin HMDA LAR quality.