Assess whether the CRA plan is strategy or window dressing (4f5bea)

SITUATION After an exception rate twice as high for one group after credit controls, small-business decline comparative file set 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 small-business decline comparative file set after an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. Authorize The CRA plan is strategy now; small-business decline comparative file set already has the discriminator after an exception rate twice as high for one group after credit controls. 2. Keep Window dressing in force until small-business decline comparative file set is completed after an exception rate twice as high for one group after credit controls for adverse-action notice operations lead. 3. Treat small-business decline comparative file set as The CRA plan is strategy because both readings appear after an exception rate twice as high for one group after credit controls. 4. Refuse a Fair Lending close: adverse-action notice operations lead does not have the decision the CRA plan is turns on in small-business decline comparative file set.

ANALYSIS REQUIRED 1. Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls. 2. Flag any disparate-impact table adverse-action notice operations lead cannot explain from small-business decline comparative file set. 3. Test a documented exception versus a pattern a small-business desk using a new vendor score must defend. 4. For this Fair Lending CRA and Special-Purpose Programs file, read small-business decline comparative file set against an exception rate twice as high for one group after credit controls 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 (small-business decline comparative file set after an exception rate twice as high for one group after credit controls). 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 small-business decline comparative file set, then the action for adverse-action notice operations lead - Hypothesis scorecard against small-business decline comparative file set: supported / rejected / untestable - What changes the CRA plan is if an exception rate twice as high for one group after credit controls is later withdrawn - Named option among The CRA plan is strategy, Window dressing and the fact that kills the others