Assess whether the CRA plan is strategy or window dressing (9d85c8)

SITUATION HMDA LAR validity and quality edits arrived with a vendor score change with no disparate-impact test for adverse-action notice operations lead. That is a Fair Lending CRA and Special-Purpose Programs decision on the CRA plan is in a small-business desk using a new vendor score.

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 HMDA LAR validity and quality edits 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 CRA and Special-Purpose Programs process in a small-business desk using a new vendor score, given HMDA LAR validity and quality edits. 2. A vendor score change with no disparate-impact test is the event in HMDA LAR validity and quality edits that forces The CRA plan is strategy for adverse-action notice operations lead under Fair Lending. 3. HMDA LAR validity and quality edits shows a one-file miss after a vendor score change with no disparate-impact test, not a CRA and Special-Purpose Programs program failure. 4. HMDA LAR validity and quality edits 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 small-business desk using a new vendor score can defend.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in HMDA LAR validity and quality edits. 2. Check HMDA coding and underwriting policy against the CRA plan is. 3. Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test. 4. For this Fair Lending CRA and Special-Purpose Programs file, read HMDA LAR validity and quality edits 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 / CRA and Special-Purpose Programs packet (HMDA LAR validity and quality edits after a vendor score change with no disparate-impact test). If HMDA LAR validity and quality edits cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If HMDA LAR validity and quality edits after a vendor score change with no disparate-impact test cannot support The CRA plan is strategy versus Window dressing on this Fair Lending CRA and Special-Purpose Programs close, adverse-action notice operations lead must do not infer a control or scheme beyond the transaction and entitlement evidence.