Assess whether the CRA plan is strategy or window dressing (fe7f4f)

SITUATION In a small-business desk using a new vendor score, SPCP written plan versus actual originations is the evidence after a marketing mailer that skipped majority-minority tracts. Adverse-action notice operations lead has to pick The CRA plan is strategy or Window dressing for this Fair Lending CRA and Special-Purpose Programs close using SPCP written plan versus actual originations.

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 SPCP written plan versus actual originations after a marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. The population in SPCP written plan versus actual originations is the one a marketing mailer that skipped majority-minority tracts named, so The CRA plan is strategy follows for this CRA and Special-Purpose Programs file. 2. The population in SPCP written plan versus actual originations is adjacent only to a marketing mailer that skipped majority-minority tracts; Window dressing is the honest Fair Lending call. 3. A small-business desk using a new vendor score already contained a marketing mailer that skipped majority-minority tracts before SPCP written plan versus actual originations arrived; no new CRA and Special-Purpose Programs path. 4. Provenance on SPCP written plan versus actual originations after a marketing mailer that skipped majority-minority tracts is broken; do not pick The CRA plan is strategy or Window dressing yet.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the CRA plan is. 2. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts. 3. Flag any disparate-impact table adverse-action notice operations lead cannot explain from SPCP written plan versus actual originations. 4. For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations against a marketing mailer that skipped majority-minority tracts 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 (SPCP written plan versus actual originations after a marketing mailer that skipped majority-minority tracts). 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 SPCP written plan versus actual originations, then the action for adverse-action notice operations lead - Hypothesis scorecard against SPCP written plan versus actual originations: supported / rejected / untestable - Owner and next date for adverse-action notice operations lead in a small-business desk using a new vendor score - What changes the CRA plan is if a marketing mailer that skipped majority-minority tracts is later withdrawn