Assess whether the CRA plan is strategy or window dressing (bb18b9)

SITUATION CRA and Special-Purpose Programs work in a credit union rolling out a special-purpose credit program now turns on the CRA plan is because a SPCP that originated almost no loans to the intended class put geographic application and origination heat map in play. CRA and Special-Purpose Programs work in a credit union rolling out a special-purpose credit program now turns on the CRA plan is because a SPCP that originated almost no loans to the intended class put geographic application and origination heat map in play; HMDA data-quality manager should say what geographic application and origination heat map proves for Fair Lending.

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 geographic application and origination heat map after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. Authorize The CRA plan is strategy now; geographic application and origination heat map already has the discriminator after a SPCP that originated almost no loans to the intended class. 2. Keep Window dressing in force until geographic application and origination heat map is completed after a SPCP that originated almost no loans to the intended class for HMDA data-quality manager. 3. Treat geographic application and origination heat map as The CRA plan is strategy because both readings appear after a SPCP that originated almost no loans to the intended class. 4. Refuse a Fair Lending close: HMDA data-quality manager does not have the decision the CRA plan is turns on in geographic application and origination heat map.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the CRA plan is. 2. Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class. 3. Flag any disparate-impact table HMDA data-quality manager cannot explain from geographic application and origination heat map. 4. For this Fair Lending CRA and Special-Purpose Programs file, read geographic application and origination heat map against a SPCP that originated almost no loans to the intended class 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 (geographic application and origination heat map after a SPCP that originated almost no loans to the intended class). Lead with the Fair Lending option geographic application and origination heat map can support after a SPCP that originated almost no loans to the intended class, then the two facts that force it, then the Monday action for HMDA data-quality manager in a credit union rolling out a special-purpose credit program.