Assess whether the CRA plan is strategy or window dressing (d8b357)

SITUATION Adverse-action notice operations lead is responsible for the CRA plan is in a small-business desk using a new vendor score, using geographic application and origination heat map as the only working extract. A HMDA resubmission that still fails quality edits is what reset the timeline for this Fair Lending CRA and Special-Purpose Programs file.

DECISION Adverse-action notice operations lead in a small-business desk using a new vendor score must choose The CRA plan is strategy / Window dressing using geographic application and origination heat map after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. Geographic application and origination heat map reads as The CRA plan is strategy once a HMDA resubmission that still fails quality edits is lined up to the same Fair Lending population. 2. Geographic application and origination heat map is closer to Window dressing after a HMDA resubmission that still fails quality edits; The CRA plan is strategy would over-claim this CRA and Special-Purpose Programs extract. 3. A dual reading is still live in geographic application and origination heat map for adverse-action notice operations lead in a small-business desk using a new vendor score. 4. Geographic application and origination heat map is missing the fact adverse-action notice operations lead needs after a HMDA resubmission that still fails quality edits; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Flag any disparate-impact table adverse-action notice operations lead cannot explain from geographic application and origination heat map. 2. Test a documented exception versus a pattern a small-business desk using a new vendor score must defend. 3. Match the adverse-action language to the facts in geographic application and origination heat map. 4. For this Fair Lending CRA and Special-Purpose Programs file, read geographic application and origination heat map against a HMDA resubmission that still fails quality edits 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 / CRA and Special-Purpose Programs packet (geographic application and origination heat map after a HMDA resubmission that still fails quality edits). The follow-on CRA and Special-Purpose Programs action is what adverse-action notice operations lead 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 geographic application and origination heat map, then the action for adverse-action notice operations lead - Hypothesis scorecard against geographic application and origination heat map: supported / rejected / untestable - Named option among The CRA plan is strategy, Window dressing and the fact that kills the others - Owner and next date for adverse-action notice operations lead in a small-business desk using a new vendor score