Assess whether the CRA plan is strategy or window dressing (7dc9ee)

SITUATION In a bank with thin HMDA LAR quality, model-reason-code mapping that does not match notices is the evidence after a notice that cites 'other' as the principal reason 40% of the time. Fair-lending officer has to pick The CRA plan is strategy or Window dressing for this Fair Lending CRA and Special-Purpose Programs close using model-reason-code mapping that does not match notices.

DECISION Fair-lending officer in a bank with thin HMDA LAR quality must choose The CRA plan is strategy / Window dressing using model-reason-code mapping that does not match notices after a notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. A notice that cites 'other' as the principal reason 40% of the time is noise around an already-controlled CRA and Special-Purpose Programs process in a bank with thin HMDA LAR quality, given model-reason-code mapping that does not match notices. 2. A notice that cites 'other' as the principal reason 40% of the time is the event in model-reason-code mapping that does not match notices that forces The CRA plan is strategy for fair-lending officer under Fair Lending. 3. Model-reason-code mapping that does not match notices shows a one-file miss after a notice that cites 'other' as the principal reason 40% of the time, not a CRA and Special-Purpose Programs program failure. 4. Model-reason-code mapping that does not match notices cannot decide the CRA plan is yet after a notice that cites 'other' as the principal reason 40% of the time; hold is the only Fair Lending close a bank with thin HMDA LAR quality can defend.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in model-reason-code mapping that does not match notices. 2. Check HMDA coding and underwriting policy against the CRA plan is. 3. Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time. 4. For this Fair Lending CRA and Special-Purpose Programs file, read model-reason-code mapping that does not match notices 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 / CRA and Special-Purpose Programs packet (model-reason-code mapping that does not match notices after a notice that cites 'other' as the principal reason 40% of the time). Lead with the Fair Lending option model-reason-code mapping that does not match notices can support after a notice that cites 'other' as the principal reason 40% of the time, then the two facts that force it, then the Monday action for fair-lending officer in a bank with thin HMDA LAR quality.