Assess whether the CRA plan is strategy or window dressing (965804)

SITUATION Underwriting exception log by branch arrived with a vendor score change with no disparate-impact test for HMDA data-quality manager. That is a Fair Lending CRA and Special-Purpose Programs decision on the CRA plan is in a credit union rolling out a special-purpose credit program.

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 underwriting exception log by branch 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 underwriting exception log by branch. 2. A vendor score change with no disparate-impact test is the event in underwriting exception log by branch that forces The CRA plan is strategy for HMDA data-quality manager under Fair Lending. 3. Underwriting exception log by branch 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. Underwriting exception log by branch 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. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 2. Match the adverse-action language to the facts in underwriting exception log by branch. 3. Check HMDA coding and underwriting policy against the CRA plan is. 4. For this Fair Lending CRA and Special-Purpose Programs file, read underwriting exception log by branch 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 (underwriting exception log by branch after a vendor score change with no disparate-impact test). The follow-on CRA and Special-Purpose Programs action is what HMDA data-quality manager 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 underwriting exception log by branch, then the action for HMDA data-quality manager - Hypothesis scorecard against underwriting exception log by branch: supported / rejected / untestable - Regulatory or exam hook CRA and Special-Purpose Programs would cite - CRA and Special-Purpose Programs finding in underwriting exception log by branch that a second reviewer can re-perform