Assess whether the CRA plan is strategy or window dressing (7a98e2)

SITUATION In a credit union rolling out a special-purpose credit program, SPCP written plan versus actual originations is the evidence after an underwriter chat that used coded language. Second-review underwriter has to pick The CRA plan is strategy or Window dressing for this Fair Lending Examination and Notices close using SPCP written plan versus actual originations.

DECISION Second-review underwriter 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 an underwriter chat that used coded language.

HYPOTHESES TO TEST 1. SPCP written plan versus actual originations reads as The CRA plan is strategy once an underwriter chat that used coded language is lined up to the same Fair Lending population. 2. SPCP written plan versus actual originations is closer to Window dressing after an underwriter chat that used coded language; The CRA plan is strategy would over-claim this Examination and Notices extract. 3. A dual reading is still live in SPCP written plan versus actual originations for second-review underwriter in a credit union rolling out a special-purpose credit program. 4. SPCP written plan versus actual originations is missing the fact second-review underwriter needs after an underwriter chat that used coded language; stop this Fair Lending close.

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 an underwriter chat that used coded language. 3. Flag any disparate-impact table second-review underwriter cannot explain from SPCP written plan versus actual originations. 4. For this Fair Lending Examination and Notices file, read SPCP written plan versus actual originations against an underwriter chat that used coded language and write the one fact that would move the CRA plan is for second-review underwriter.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / Examination and Notices packet (SPCP written plan versus actual originations after an underwriter chat that used coded language). The follow-on Examination and Notices action is what second-review underwriter 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 second-review underwriter - Hypothesis scorecard against SPCP written plan versus actual originations: supported / rejected / untestable - What changes the CRA plan is if an underwriter chat that used coded language is later withdrawn - Named option among The CRA plan is strategy, Window dressing and the fact that kills the others