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

Situation

After an underwriter chat that used coded language, credit-card limit assignment disparity table is what fair-lending officer can touch in a bank with thin HMDA LAR quality. Fair Lending will live with A special-purpose program is well designed versus A pretext on this CRA and Special-Purpose Programs file.

Decision

Fair-lending officer in a bank with thin HMDA LAR quality must choose A special-purpose program is well designed / A pretext using credit-card limit assignment disparity table after an underwriter chat that used coded language.

Hypotheses to test

• Authorize A special-purpose program is well designed now; credit-card limit assignment disparity table already has the discriminator after an underwriter chat that used coded language.
• Keep A pretext in force until credit-card limit assignment disparity table is completed after an underwriter chat that used coded language for fair-lending officer.
• Treat credit-card limit assignment disparity table as A special-purpose program is well designed because both readings appear after an underwriter chat that used coded language.
• Refuse a Fair Lending close: fair-lending officer does not have the page a special-purpose program is turns on in credit-card limit assignment disparity table.

Analysis required

• Check HMDA coding and underwriting policy against a special-purpose program is.
• Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language.
• Flag any disparate-impact table fair-lending officer cannot explain from credit-card limit assignment disparity table.
• For this Fair Lending CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table against an underwriter chat that used coded language 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 (credit-card limit assignment disparity table after an underwriter chat that used coded language). Lead with the Fair Lending option credit-card limit assignment disparity table can support after an underwriter chat that used coded language, then the two facts that force it, then the Monday action for fair-lending officer in a bank with thin HMDA LAR quality.