Whether the CRA plan is strategy or window dressing from SPCP written plan

Situation

The CRA plan is sits with HMDA data-quality manager because a branch that stopped taking applications in one ZIP hit a credit-card issuer changing line-assignment logic. Evidence is SPCP written plan versus actual originations; write the Fair Lending Redlining and HMDA Data option that extract can carry.

Decision

HMDA data-quality manager in a credit-card issuer changing line-assignment logic must choose The CRA plan is strategy / Window dressing using SPCP written plan versus actual originations after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• HMDA data-quality manager can defend The CRA plan is strategy from SPCP written plan versus actual originations after a branch that stopped taking applications in one ZIP in a Fair Lending challenge.
• HMDA data-quality manager cannot defend The CRA plan is strategy from SPCP written plan versus actual originations; Window dressing is what the extract actually supports after a branch that stopped taking applications in one ZIP.
• A branch that stopped taking applications in one ZIP never reached the population in SPCP written plan versus actual originations — reopen intake, do not close the CRA plan is.
• Two facts in SPCP written plan versus actual originations after a branch that stopped taking applications in one ZIP conflict for HMDA data-quality manager; hold this Redlining and HMDA Data file.

Analysis required

• Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend.
• Match the adverse-action language to the facts in SPCP written plan versus actual originations.
• Check HMDA coding and underwriting policy against the CRA plan is.
• For this Fair Lending Redlining and HMDA Data file, read SPCP written plan versus actual originations against a branch that stopped taking applications in one ZIP 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 (SPCP written plan versus actual originations after a branch that stopped taking applications in one ZIP). If SPCP written plan versus actual originations cannot force a Fair Lending label under Redlining and HMDA Data, stop. If SPCP written plan versus actual originations after a branch that stopped taking applications in one ZIP cannot support The CRA plan is strategy versus Window dressing on this Fair Lending Redlining and HMDA Data close, HMDA data-quality manager must do not infer a control or scheme beyond the transaction and entitlement evidence.