Assess whether the CRA plan is strategy or window dressing from CRA

SITUATION After a vendor score change with no disparate-impact test, CRA assessment-area versus lending footprint 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 CRA assessment-area versus lending footprint after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. A vendor score change with no disparate-impact test is noise around an already-controlled Pricing and Credit Limits process in a credit union rolling out a special-purpose credit program, given CRA assessment-area versus lending footprint. 2. A vendor score change with no disparate-impact test is the event in CRA assessment-area versus lending footprint that forces The CRA plan is strategy for adverse-action notice operations lead under Fair Lending. 3. CRA assessment-area versus lending footprint shows a one-file miss after a vendor score change with no disparate-impact test, not a Pricing and Credit Limits program failure. 4. CRA assessment-area versus lending footprint cannot decide the CRA plan is yet after a vendor score change with no disparate-impact test; hold is the only Fair Lending close a credit union rolling out a special-purpose credit program can defend.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 2. Match the adverse-action language to the facts in CRA assessment-area versus lending footprint. 3. Check HMDA coding and underwriting policy against the CRA plan is. 4. For this Fair Lending Pricing and Credit Limits file, read CRA assessment-area versus lending footprint against a vendor score change with no disparate-impact test 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 (CRA assessment-area versus lending footprint after a vendor score change with no disparate-impact test). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for adverse-action notice operations lead in a credit union rolling out a special-purpose credit program.

COMMAND RETURNS - Bottom-line Fair Lending option on the CRA plan is, then the evidence in CRA assessment-area versus lending footprint, then the action for adverse-action notice operations lead - Hypothesis scorecard against CRA assessment-area versus lending footprint: supported / rejected / untestable - Regulatory or exam hook Pricing and Credit Limits would cite - Pricing and Credit Limits finding in CRA assessment-area versus lending footprint that a second reviewer can re-perform