Assess whether the CRA plan is strategy or window dressing (d68aad)

SITUATION After a CRA PE that called the assessment area too narrow, model-reason-code mapping that does not match notices is what adverse-action notice operations lead can touch in a small-business desk using a new vendor score. Fair Lending will live with The CRA plan is strategy versus Window dressing on this 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 model-reason-code mapping that does not match notices after a CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. A CRA PE that called the assessment area too narrow is noise around an already-controlled CRA and Special-Purpose Programs process in a small-business desk using a new vendor score, given model-reason-code mapping that does not match notices. 2. A CRA PE that called the assessment area too narrow is the event in model-reason-code mapping that does not match notices that forces The CRA plan is strategy for adverse-action notice operations lead under Fair Lending. 3. Model-reason-code mapping that does not match notices shows a one-file miss after a CRA PE that called the assessment area too narrow, 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 CRA PE that called the assessment area too narrow; hold is the only Fair Lending close a small-business desk using a new vendor score can defend.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a small-business desk using a new vendor score 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 CRA and Special-Purpose Programs file, read model-reason-code mapping that does not match notices against a CRA PE that called the assessment area too narrow 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 (model-reason-code mapping that does not match notices after a CRA PE that called the assessment area too narrow). 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 model-reason-code mapping that does not match notices, then the action for adverse-action notice operations lead - Hypothesis scorecard against model-reason-code mapping that does not match notices: 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