Assess whether the CRA plan is strategy or window dressing (81b2c4)

SITUATION Credit-card limit assignment disparity table arrived with an exception rate twice as high for one group after credit controls for second-review underwriter. That is a Fair Lending CRA and Special-Purpose Programs decision on the CRA plan is in a lender expanding into majority-minority census tracts.

DECISION Second-review underwriter in a lender expanding into majority-minority census tracts must choose The CRA plan is strategy / Window dressing using credit-card limit assignment disparity table after an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. Second-review underwriter can defend The CRA plan is strategy from credit-card limit assignment disparity table after an exception rate twice as high for one group after credit controls in a Fair Lending challenge. 2. Second-review underwriter cannot defend The CRA plan is strategy from credit-card limit assignment disparity table; Window dressing is what the extract actually supports after an exception rate twice as high for one group after credit controls. 3. An exception rate twice as high for one group after credit controls never reached the population in credit-card limit assignment disparity table — reopen intake, do not close the CRA plan is. 4. Two facts in credit-card limit assignment disparity table after an exception rate twice as high for one group after credit controls conflict for second-review underwriter; hold this CRA and Special-Purpose Programs file.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 2. Match the adverse-action language to the facts in credit-card limit assignment disparity table. 3. Check HMDA coding and underwriting policy against the CRA plan is. 4. For this Fair Lending CRA and Special-Purpose Programs file, read credit-card limit assignment disparity table against an exception rate twice as high for one group after credit controls 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 / CRA and Special-Purpose Programs packet (credit-card limit assignment disparity table after an exception rate twice as high for one group after credit controls). Lead with the Fair Lending option credit-card limit assignment disparity table can support after an exception rate twice as high for one group after credit controls, then the two facts that force it, then the Monday action for second-review underwriter in a lender expanding into majority-minority census tracts.

COMMAND RETURNS - Bottom-line Fair Lending option on the CRA plan is, then the evidence in credit-card limit assignment disparity table, then the action for second-review underwriter - Hypothesis scorecard against credit-card limit assignment disparity table: supported / rejected / untestable - Regulatory or exam hook CRA and Special-Purpose Programs would cite - CRA and Special-Purpose Programs finding in credit-card limit assignment disparity table that a second reviewer can re-perform