Assess whether the CRA plan is strategy or window dressing (8d1b2e)

SITUATION CRA strategist in a bank with thin HMDA LAR quality has one working extract — credit-card limit assignment disparity table — after a HMDA resubmission that still fails quality edits. CRA strategist in a bank with thin HMDA LAR quality has credit-card limit assignment disparity table after a HMDA resubmission that still fails quality edits. If that extract cannot support the CRA plan is, the only defensible Fair Lending Examination and Notices output is hold.

DECISION CRA strategist in a bank with thin HMDA LAR quality must choose The CRA plan is strategy / Window dressing using credit-card limit assignment disparity table after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. Authorize The CRA plan is strategy now; credit-card limit assignment disparity table already has the discriminator after a HMDA resubmission that still fails quality edits. 2. Keep Window dressing in force until credit-card limit assignment disparity table is completed after a HMDA resubmission that still fails quality edits for CRA strategist. 3. Treat credit-card limit assignment disparity table as The CRA plan is strategy because both readings appear after a HMDA resubmission that still fails quality edits. 4. Refuse a Fair Lending close: CRA strategist does not have the decision the CRA plan is turns on in credit-card limit assignment disparity table.

ANALYSIS REQUIRED 1. Flag any disparate-impact table CRA strategist cannot explain from credit-card limit assignment disparity table. 2. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 3. Match the adverse-action language to the facts in credit-card limit assignment disparity table. 4. For this Fair Lending Examination and Notices file, read credit-card limit assignment disparity table against a HMDA resubmission that still fails quality edits and write the one fact that would move the CRA plan is for CRA strategist.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / Examination and Notices packet (credit-card limit assignment disparity table after a HMDA resubmission that still fails quality edits). The follow-on Examination and Notices action is what CRA strategist 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 credit-card limit assignment disparity table, then the action for CRA strategist - Hypothesis scorecard against credit-card limit assignment disparity table: supported / rejected / untestable - Owner and next date for CRA strategist in a bank with thin HMDA LAR quality - What changes the CRA plan is if a HMDA resubmission that still fails quality edits is later withdrawn