Assess whether the CRA plan is strategy or window dressing (182611)

SITUATION CRA and Special-Purpose Programs work in a small-business desk using a new vendor score now turns on the CRA plan is because a SPCP that originated almost no loans to the intended class put SPCP written plan versus actual originations in play. Adverse-action notice operations lead should say what SPCP written plan versus actual originations proves.

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 SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. The population in SPCP written plan versus actual originations is the one a SPCP that originated almost no loans to the intended class 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 SPCP that originated almost no loans to the intended class; Window dressing is the honest Fair Lending call. 3. A small-business desk using a new vendor score already contained a SPCP that originated almost no loans to the intended class 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 SPCP that originated almost no loans to the intended class is broken; do not pick The CRA plan is strategy or Window dressing yet.

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 SPCP that originated almost no loans to the intended class. 4. For this Fair Lending CRA and Special-Purpose Programs file, read SPCP written plan versus actual originations against a SPCP that originated almost no loans to the intended class 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 SPCP that originated almost no loans to the intended class). 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 - What changes the CRA plan is if a SPCP that originated almost no loans to the intended class is later withdrawn - Named option among The CRA plan is strategy, Window dressing and the fact that kills the others