Assess whether the CRA plan is strategy or window dressing (47ec90)

SITUATION After a branch that stopped taking applications in one ZIP, model-reason-code mapping that does not match notices is what model-risk partner for credit scoring can touch in a lender expanding into majority-minority census tracts. Fair Lending will live with The CRA plan is strategy versus Window dressing on this Examination and Notices file.

DECISION Model-risk partner for credit scoring in a lender expanding into majority-minority census tracts must choose The CRA plan is strategy / Window dressing using model-reason-code mapping that does not match notices after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. Authorize The CRA plan is strategy now; model-reason-code mapping that does not match notices already has the discriminator after a branch that stopped taking applications in one ZIP. 2. Keep Window dressing in force until model-reason-code mapping that does not match notices is completed after a branch that stopped taking applications in one ZIP for model-risk partner for credit scoring. 3. Treat model-reason-code mapping that does not match notices as The CRA plan is strategy because both readings appear after a branch that stopped taking applications in one ZIP. 4. Refuse a Fair Lending close: model-risk partner for credit scoring does not have the decision the CRA plan is turns on in model-reason-code mapping that does not match notices.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 2. Match the adverse-action language to the facts in model-reason-code mapping that does not match notices. 3. Check HMDA coding and underwriting policy against the CRA plan is. 4. For this Fair Lending Examination and Notices file, read model-reason-code mapping that does not match notices against a branch that stopped taking applications in one ZIP and write the one fact that would move the CRA plan is for model-risk partner for credit scoring.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / Examination and Notices packet (model-reason-code mapping that does not match notices after a branch that stopped taking applications in one ZIP). The follow-on Examination and Notices action is what model-risk partner for credit scoring 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 model-reason-code mapping that does not match notices, then the action for model-risk partner for credit scoring - Hypothesis scorecard against model-reason-code mapping that does not match notices: supported / rejected / untestable - Owner and next date for model-risk partner for credit scoring in a lender expanding into majority-minority census tracts - What changes the CRA plan is if a branch that stopped taking applications in one ZIP is later withdrawn