Assess whether the CRA plan is strategy or window dressing (807f7e)

SITUATION A vendor score change with no disparate-impact test put SPCP written plan versus actual originations in front of HMDA data-quality manager in a credit union rolling out a special-purpose credit program. This Fair Lending / CRA and Special-Purpose Programs decision is the CRA plan is from SPCP written plan versus actual originations, and the live options are The CRA plan is strategy, Window dressing.

DECISION HMDA data-quality manager in a credit union rolling out a special-purpose credit program must choose The CRA plan is strategy / Window dressing using SPCP written plan versus actual originations after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. A vendor score change with no disparate-impact test is noise around an already-controlled CRA and Special-Purpose Programs process in a credit union rolling out a special-purpose credit program, given SPCP written plan versus actual originations. 2. A vendor score change with no disparate-impact test is the event in SPCP written plan versus actual originations that forces The CRA plan is strategy for HMDA data-quality manager under Fair Lending. 3. SPCP written plan versus actual originations shows a one-file miss after a vendor score change with no disparate-impact test, not a CRA and Special-Purpose Programs program failure. 4. SPCP written plan versus actual originations cannot decide the CRA plan is yet after a vendor score change with no disparate-impact test; hold is the only Fair Lending close a credit union rolling out a special-purpose credit program can defend.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in SPCP written plan versus actual originations. 2. Check HMDA coding and underwriting policy against the CRA plan is. 3. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test. 4. For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations 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 / CRA and Special-Purpose Programs packet (SPCP written plan versus actual originations after a vendor score change with no disparate-impact test). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a vendor score change with no disparate-impact test, then the two facts that force it, then the Monday action for HMDA data-quality manager in a credit union rolling out a special-purpose credit program.