Assess whether the CRA plan is strategy or window dressing (da4694)

SITUATION Appraisal-gap outcomes in majority-minority tracts arrived with a board asking if the bank should settle a matched-pair study. Model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program still has an evidence gap on whether the CRA plan is strategy or window dressing.

DECISION Model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program must choose The CRA plan is strategy / Window dressing using appraisal-gap outcomes in majority-minority tracts after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. Authorize The CRA plan is strategy now; appraisal-gap outcomes in majority-minority tracts already has the discriminator after a board asking if the bank should settle a matched-pair study. 2. Keep Window dressing in force until appraisal-gap outcomes in majority-minority tracts is completed after a board asking if the bank should settle a matched-pair study for model-risk partner for credit scoring. 3. Treat appraisal-gap outcomes in majority-minority tracts as The CRA plan is strategy because both readings appear after a board asking if the bank should settle a matched-pair study. 4. Refuse a Fair Lending close: model-risk partner for credit scoring does not have the decision the CRA plan is turns on in appraisal-gap outcomes in majority-minority tracts.

ANALYSIS REQUIRED 1. Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study. 2. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from appraisal-gap outcomes in majority-minority tracts. 3. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 4. For this Fair Lending Redlining and HMDA Data file, read appraisal-gap outcomes in majority-minority tracts against a board asking if the bank should settle a matched-pair study and write the one fact that would move the CRA plan is for model-risk partner for credit scoring.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / Redlining and HMDA Data packet (appraisal-gap outcomes in majority-minority tracts after a board asking if the bank should settle a matched-pair study). The follow-on Redlining and HMDA Data action is what model-risk partner for credit scoring 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 appraisal-gap outcomes in majority-minority tracts, then the action for model-risk partner for credit scoring - Hypothesis scorecard against appraisal-gap outcomes in majority-minority tracts: supported / rejected / untestable - Redlining and HMDA Data finding in appraisal-gap outcomes in majority-minority tracts that a second reviewer can re-perform - Missing page in appraisal-gap outcomes in majority-minority tracts after a board asking if the bank should settle a matched-pair study, if any