Assess whether the CRA plan is strategy or window dressing (aa23f4)

SITUATION In a small-business desk using a new vendor score, adverse-action notice principal-reason sample is the evidence after a notice that cites 'other' as the principal reason 40% of the time. HMDA data-quality manager has to pick The CRA plan is strategy or Window dressing for this Fair Lending Examination and Notices close using adverse-action notice principal-reason sample.

DECISION HMDA data-quality manager in a small-business desk using a new vendor score must choose The CRA plan is strategy / Window dressing using adverse-action notice principal-reason sample after a notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. HMDA data-quality manager can defend The CRA plan is strategy from adverse-action notice principal-reason sample after a notice that cites 'other' as the principal reason 40% of the time in a Fair Lending challenge. 2. HMDA data-quality manager cannot defend The CRA plan is strategy from adverse-action notice principal-reason sample; Window dressing is what the extract actually supports after a notice that cites 'other' as the principal reason 40% of the time. 3. A notice that cites 'other' as the principal reason 40% of the time never reached the population in adverse-action notice principal-reason sample — reopen intake, do not close the CRA plan is. 4. Two facts in adverse-action notice principal-reason sample after a notice that cites 'other' as the principal reason 40% of the time conflict for HMDA data-quality manager; hold this Examination and Notices file.

ANALYSIS REQUIRED 1. Flag any disparate-impact table HMDA data-quality manager cannot explain from adverse-action notice principal-reason sample. 2. Test a documented exception versus a pattern a small-business desk using a new vendor score must defend. 3. Match the adverse-action language to the facts in adverse-action notice principal-reason sample. 4. For this Fair Lending Examination and Notices file, read adverse-action notice principal-reason sample against a notice that cites 'other' as the principal reason 40% of the time 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 / Examination and Notices packet (adverse-action notice principal-reason sample after a notice that cites 'other' as the principal reason 40% of the time). Lead with the Fair Lending option adverse-action notice principal-reason sample can support after a notice that cites 'other' as the principal reason 40% of the time, then the two facts that force it, then the Monday action for HMDA data-quality manager in a small-business desk using a new vendor score.