Whether the CRA plan is strategy or window dressing from mortgage pricing

SITUATION After an underwriter chat that used coded language, mortgage pricing residual by prohibited-basis group is what adverse-action notice operations lead can touch in a credit union rolling out a special-purpose credit program. Fair Lending will live with The CRA plan is strategy versus Window dressing on this Pricing and Credit Limits file.

DECISION Adverse-action notice operations lead in a credit union rolling out a special-purpose credit program must choose The CRA plan is strategy / Window dressing using mortgage pricing residual by prohibited-basis group after an underwriter chat that used coded language.

HYPOTHESES TO TEST 1. The population in mortgage pricing residual by prohibited-basis group is the one an underwriter chat that used coded language named, so The CRA plan is strategy follows for this Pricing and Credit Limits file. 2. The population in mortgage pricing residual by prohibited-basis group is adjacent only to an underwriter chat that used coded language; Window dressing is the honest Fair Lending call. 3. A credit union rolling out a special-purpose credit program already contained an underwriter chat that used coded language before mortgage pricing residual by prohibited-basis group arrived; no new Pricing and Credit Limits path. 4. Provenance on mortgage pricing residual by prohibited-basis group after an underwriter chat that used coded language is broken; do not pick The CRA plan is strategy or Window dressing yet.

ANALYSIS REQUIRED 1. Flag any disparate-impact table adverse-action notice operations lead cannot explain from mortgage pricing residual by prohibited-basis group. 2. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 3. Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group. 4. For this Fair Lending Pricing and Credit Limits file, read mortgage pricing residual by prohibited-basis group against an underwriter chat that used coded language and write the one fact that would move the CRA plan is for adverse-action notice operations lead.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / Pricing and Credit Limits packet (mortgage pricing residual by prohibited-basis group after an underwriter chat that used coded language). The follow-on Pricing and Credit Limits action is what adverse-action notice operations lead does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on the CRA plan is, then the evidence in mortgage pricing residual by prohibited-basis group, then the action for adverse-action notice operations lead - Hypothesis scorecard against mortgage pricing residual by prohibited-basis group: supported / rejected / untestable - What changes the CRA plan is if an underwriter chat that used coded language is later withdrawn - Named option among The CRA plan is strategy, Window dressing and the fact that kills the others