Assess whether the CRA plan is strategy or window dressing (42eb49)

SITUATION An exception rate twice as high for one group after credit controls put adverse-action notice principal-reason sample in front of HMDA data-quality manager in a credit union rolling out a special-purpose credit program. This Fair Lending / CRA and Special-Purpose Programs decision is the CRA plan is from adverse-action notice principal-reason sample, and the live options are The CRA plan is strategy, Window dressing.

DECISION HMDA data-quality manager 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 an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. Adverse-action notice principal-reason sample reads as The CRA plan is strategy once an exception rate twice as high for one group after credit controls is lined up to the same Fair Lending population. 2. Adverse-action notice principal-reason sample is closer to Window dressing after an exception rate twice as high for one group after credit controls; The CRA plan is strategy would over-claim this CRA and Special-Purpose Programs extract. 3. A dual reading is still live in adverse-action notice principal-reason sample for HMDA data-quality manager in a credit union rolling out a special-purpose credit program. 4. Adverse-action notice principal-reason sample is missing the fact HMDA data-quality manager needs after an exception rate twice as high for one group after credit controls; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls. 2. Flag any disparate-impact table HMDA data-quality manager cannot explain from adverse-action notice principal-reason sample. 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 CRA and Special-Purpose Programs file, read adverse-action notice principal-reason sample against an exception rate twice as high for one group after credit controls and write the one fact that would move the CRA plan is for HMDA data-quality manager.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / CRA and Special-Purpose Programs packet (adverse-action notice principal-reason sample after an exception rate twice as high for one group after credit controls). If adverse-action notice principal-reason sample cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If adverse-action notice principal-reason sample after an exception rate twice as high for one group after credit controls cannot support The CRA plan is strategy versus Window dressing on this Fair Lending CRA and Special-Purpose Programs close, HMDA data-quality manager must do not infer a control or scheme beyond the transaction and entitlement evidence.