Assess whether the CRA plan is strategy or window dressing (f9b522)

SITUATION A credit union rolling out a special-purpose credit program cannot treat a SPCP that originated almost no loans to the intended class as incidental context on adverse-action notice principal-reason sample. Second-review underwriter must close the CRA plan is from that extract under Fair Lending / Examination and Notices.

DECISION Second-review underwriter in a credit union rolling out a special-purpose credit program must choose The CRA plan is strategy / Window dressing using adverse-action notice principal-reason sample after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. Adverse-action notice principal-reason sample reads as The CRA plan is strategy once a SPCP that originated almost no loans to the intended class is lined up to the same Fair Lending population. 2. Adverse-action notice principal-reason sample is closer to Window dressing after a SPCP that originated almost no loans to the intended class; The CRA plan is strategy would over-claim this Examination and Notices extract. 3. A dual reading is still live in adverse-action notice principal-reason sample for second-review underwriter in a credit union rolling out a special-purpose credit program. 4. Adverse-action notice principal-reason sample is missing the fact second-review underwriter needs after a SPCP that originated almost no loans to the intended class; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the CRA plan is. 2. Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class. 3. Flag any disparate-impact table second-review underwriter cannot explain from adverse-action notice principal-reason sample. 4. For this Fair Lending Examination and Notices file, read adverse-action notice principal-reason sample against a SPCP that originated almost no loans to the intended class and write the one fact that would move the CRA plan is for second-review underwriter.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / Examination and Notices packet (adverse-action notice principal-reason sample after a SPCP that originated almost no loans to the intended class). The follow-on Examination and Notices action is what second-review underwriter 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 adverse-action notice principal-reason sample, then the action for second-review underwriter - Hypothesis scorecard against adverse-action notice principal-reason sample: supported / rejected / untestable - Owner and next date for second-review underwriter in a credit union rolling out a special-purpose credit program - What changes the CRA plan is if a SPCP that originated almost no loans to the intended class is later withdrawn