Assess whether the CRA plan is strategy or window dressing from mortgage

SITUATION In a credit union rolling out a special-purpose credit program, mortgage pricing residual by prohibited-basis group is the evidence after a SPCP that originated almost no loans to the intended class. Adverse-action notice operations lead has to pick The CRA plan is strategy or Window dressing for this Fair Lending Pricing and Credit Limits close using mortgage pricing residual by prohibited-basis group.

DECISION Adverse-action notice operations lead in a credit union rolling out a special-purpose credit program must choose The CRA plan is strategy / Window dressing using mortgage pricing residual by prohibited-basis group after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. The population in mortgage pricing residual by prohibited-basis group is the one a SPCP that originated almost no loans to the intended class named, so The CRA plan is strategy follows for this Pricing and Credit Limits file. 2. The population in mortgage pricing residual by prohibited-basis group is adjacent only to a SPCP that originated almost no loans to the intended class; Window dressing is the honest Fair Lending call. 3. A credit union rolling out a special-purpose credit program already contained a SPCP that originated almost no loans to the intended class before mortgage pricing residual by prohibited-basis group arrived; no new Pricing and Credit Limits path. 4. Provenance on mortgage pricing residual by prohibited-basis group after a SPCP that originated almost no loans to the intended class is broken; do not pick The CRA plan is strategy or Window dressing yet.

ANALYSIS REQUIRED 1. Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class. 2. Flag any disparate-impact table adverse-action notice operations lead cannot explain from mortgage pricing residual by prohibited-basis group. 3. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 4. For this Fair Lending Pricing and Credit Limits file, read mortgage pricing residual by prohibited-basis group against a SPCP that originated almost no loans to the intended class 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 / Pricing and Credit Limits packet (mortgage pricing residual by prohibited-basis group after a SPCP that originated almost no loans to the intended class). The follow-on Pricing and Credit Limits action is what adverse-action notice operations lead does next: implement the option, assign an owner, and log the missing fact.