Assess whether the CRA plan is strategy or window dressing (31010b)

SITUATION After an underwriter chat that used coded language, CRA assessment-area versus lending footprint is what HMDA data-quality manager can touch in a small-business desk using a new vendor score. Fair Lending will live with The CRA plan is strategy versus Window dressing on this 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 CRA assessment-area versus lending footprint after an underwriter chat that used coded language.

HYPOTHESES TO TEST 1. CRA assessment-area versus lending footprint reads as The CRA plan is strategy once an underwriter chat that used coded language is lined up to the same Fair Lending population. 2. CRA assessment-area versus lending footprint is closer to Window dressing after an underwriter chat that used coded language; The CRA plan is strategy would over-claim this Examination and Notices extract. 3. A dual reading is still live in CRA assessment-area versus lending footprint for HMDA data-quality manager in a small-business desk using a new vendor score. 4. CRA assessment-area versus lending footprint is missing the fact HMDA data-quality manager needs after an underwriter chat that used coded language; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the CRA plan is. 2. Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language. 3. Flag any disparate-impact table HMDA data-quality manager cannot explain from CRA assessment-area versus lending footprint. 4. For this Fair Lending Examination and Notices file, read CRA assessment-area versus lending footprint against an underwriter chat that used coded language 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 (CRA assessment-area versus lending footprint after an underwriter chat that used coded language). The follow-on Examination and Notices action is what HMDA data-quality manager 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 CRA assessment-area versus lending footprint, then the action for HMDA data-quality manager - Hypothesis scorecard against CRA assessment-area versus lending footprint: supported / rejected / untestable - What changes the CRA plan is if an underwriter chat that used coded language is later withdrawn - Named option among The CRA plan is strategy, Window dressing and the fact that kills the others