Assess whether the CRA plan is strategy or window dressing (ceb9d8)

SITUATION A live Fair Lending Redlining and HMDA Data file in a credit union rolling out a special-purpose credit program now turns on CRA assessment-area versus lending footprint after a community complaint about appraisal gaps. Model-risk partner for credit scoring should state what that extract proves for whether the CRA plan is strategy or window dressing.

DECISION Model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program must choose The CRA plan is strategy / Window dressing using CRA assessment-area versus lending footprint after a community complaint about appraisal gaps.

HYPOTHESES TO TEST 1. CRA assessment-area versus lending footprint reads as The CRA plan is strategy once a community complaint about appraisal gaps is lined up to the same Fair Lending population. 2. CRA assessment-area versus lending footprint is closer to Window dressing after a community complaint about appraisal gaps; The CRA plan is strategy would over-claim this Redlining and HMDA Data extract. 3. A dual reading is still live in CRA assessment-area versus lending footprint for model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program. 4. CRA assessment-area versus lending footprint is missing the fact model-risk partner for credit scoring needs after a community complaint about appraisal gaps; stop this Fair Lending close.

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 CRA assessment-area versus lending footprint. 3. Check HMDA coding and underwriting policy against the CRA plan is. 4. For this Fair Lending Redlining and HMDA Data file, read CRA assessment-area versus lending footprint against a community complaint about appraisal gaps and write the one fact that would move the CRA plan is for model-risk partner for credit scoring.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / Redlining and HMDA Data packet (CRA assessment-area versus lending footprint after a community complaint about appraisal gaps). The follow-on Redlining and HMDA Data action is what model-risk partner for credit scoring 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 CRA assessment-area versus lending footprint, then the action for model-risk partner for credit scoring - Hypothesis scorecard against CRA assessment-area versus lending footprint: supported / rejected / untestable - Named option among The CRA plan is strategy, Window dressing and the fact that kills the others - Owner and next date for model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program