Assess whether the CRA plan is strategy or window dressing (c21844)

SITUATION The Examination and Notices working file is adverse-action notice principal-reason sample after a vendor score change with no disparate-impact test. HMDA data-quality manager in a small-business desk using a new vendor score must name The CRA plan is strategy or Window dressing for this Fair Lending file. HMDA data-quality manager in a small-business desk using a new vendor score has to name The CRA plan is strategy or Window dressing for this Fair Lending Examination and Notices file.

DECISION HMDA data-quality manager in a small-business desk using a new vendor score must choose The CRA plan is strategy / Window dressing using adverse-action notice principal-reason sample after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. The population in adverse-action notice principal-reason sample is the one a vendor score change with no disparate-impact test named, so The CRA plan is strategy follows for this Examination and Notices file. 2. The population in adverse-action notice principal-reason sample is adjacent only to a vendor score change with no disparate-impact test; Window dressing is the honest Fair Lending call. 3. A small-business desk using a new vendor score already contained a vendor score change with no disparate-impact test before adverse-action notice principal-reason sample arrived; no new Examination and Notices path. 4. Provenance on adverse-action notice principal-reason sample after a vendor score change with no disparate-impact test is broken; do not pick The CRA plan is strategy or Window dressing yet.

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 vendor score change with no disparate-impact test. 3. Flag any disparate-impact table HMDA data-quality manager 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 vendor score change with no disparate-impact test 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 / Examination and Notices packet (adverse-action notice principal-reason sample after a vendor score change with no disparate-impact test). If adverse-action notice principal-reason sample cannot force a Fair Lending label under Examination and Notices, stop. If adverse-action notice principal-reason sample after a vendor score change with no disparate-impact test cannot support The CRA plan is strategy versus Window dressing on this Fair Lending Examination and Notices close, HMDA data-quality manager must do not infer a control or scheme beyond the transaction and entitlement evidence.