Assess whether the CRA plan is strategy or window dressing (349225)

SITUATION A live Fair Lending Examination and Notices file in an institution preparing for a redlining exam now turns on credit-card limit assignment disparity table after a notice that cites 'other' as the principal reason 40% of the time. Fair-lending officer should state what that extract proves for whether the CRA plan is strategy or window dressing.

DECISION Fair-lending officer in an institution preparing for a redlining exam must choose The CRA plan is strategy, Window dressing using credit-card limit assignment disparity table after a notice that cites 'other' as the principal reason 40% of the time. The question on that file is whether the CRA plan is strategy or window dressing.

HYPOTHESES TO TEST 1. Authorize The CRA plan is strategy now; credit-card limit assignment disparity table already has the discriminator after a notice that cites 'other' as the principal reason 40% of the time. 2. Keep Window dressing in force until credit-card limit assignment disparity table is completed after a notice that cites 'other' as the principal reason 40% of the time for fair-lending officer. 3. Treat credit-card limit assignment disparity table as The CRA plan is strategy because both readings appear after a notice that cites 'other' as the principal reason 40% of the time. 4. Refuse a Fair Lending close: fair-lending officer does not have the decision the CRA plan is turns on in credit-card limit assignment disparity table.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the CRA plan is. 2. Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time. 3. Flag any disparate-impact table fair-lending officer cannot explain from credit-card limit assignment disparity table. 4. For this Fair Lending Examination and Notices file, read credit-card limit assignment disparity table against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move the CRA plan is for fair-lending officer.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / Examination and Notices packet (credit-card limit assignment disparity table after a notice that cites 'other' as the principal reason 40% of the time). The follow-on Examination and Notices action is what fair-lending officer 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 credit-card limit assignment disparity table, then the action for fair-lending officer - Hypothesis scorecard against credit-card limit assignment disparity table: supported / rejected / untestable - What changes the CRA plan is if a notice that cites 'other' as the principal reason 40% of the time is later withdrawn - Named option among The CRA plan is strategy, Window dressing and the fact that kills the others