Assess whether the CRA plan is strategy or window dressing (c05a12)

SITUATION After a vendor score change with no disparate-impact test, model-reason-code mapping that does not match notices is what HMDA data-quality manager can touch in a credit-card issuer changing line-assignment logic. Fair Lending will live with The CRA plan is strategy versus Window dressing on this Redlining and HMDA Data file.

DECISION HMDA data-quality manager in a credit-card issuer changing line-assignment logic must choose The CRA plan is strategy / Window dressing using model-reason-code mapping that does not match notices after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. Model-reason-code mapping that does not match notices reads as The CRA plan is strategy once a vendor score change with no disparate-impact test is lined up to the same Fair Lending population. 2. Model-reason-code mapping that does not match notices is closer to Window dressing after a vendor score change with no disparate-impact test; The CRA plan is strategy would over-claim this Redlining and HMDA Data extract. 3. A dual reading is still live in model-reason-code mapping that does not match notices for HMDA data-quality manager in a credit-card issuer changing line-assignment logic. 4. Model-reason-code mapping that does not match notices is missing the fact HMDA data-quality manager needs after a vendor score change with no disparate-impact test; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the CRA plan is. 2. Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test. 3. Flag any disparate-impact table HMDA data-quality manager cannot explain from model-reason-code mapping that does not match notices. 4. For this Fair Lending Redlining and HMDA Data file, read model-reason-code mapping that does not match notices against a vendor score change with no disparate-impact test and write the one fact that would move the CRA plan is for HMDA data-quality manager.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / Redlining and HMDA Data packet (model-reason-code mapping that does not match notices after a vendor score change with no disparate-impact test). The follow-on Redlining and HMDA Data action is what HMDA data-quality manager 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 HMDA data-quality manager - Hypothesis scorecard against model-reason-code mapping that does not match notices: supported / rejected / untestable - What changes the CRA plan is if a vendor score change with no disparate-impact test is later withdrawn - Named option among The CRA plan is strategy, Window dressing and the fact that kills the others