Assess whether the CRA plan is strategy or window dressing (27b474)

SITUATION A notice that cites 'other' as the principal reason 40% of the time put geographic application and origination heat map in front of second-review underwriter in a small-business desk using a new vendor score. This Fair Lending / Redlining and HMDA Data decision is the CRA plan is from geographic application and origination heat map, and the live options are The CRA plan is strategy, Window dressing.

DECISION Second-review underwriter in a small-business desk using a new vendor score must choose The CRA plan is strategy / Window dressing using geographic application and origination heat map after a notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. The population in geographic application and origination heat map is the one a notice that cites 'other' as the principal reason 40% of the time named, so The CRA plan is strategy follows for this Redlining and HMDA Data file. 2. The population in geographic application and origination heat map is adjacent only to a notice that cites 'other' as the principal reason 40% of the time; Window dressing is the honest Fair Lending call. 3. A small-business desk using a new vendor score already contained a notice that cites 'other' as the principal reason 40% of the time before geographic application and origination heat map arrived; no new Redlining and HMDA Data path. 4. Provenance on geographic application and origination heat map after a notice that cites 'other' as the principal reason 40% of the time is broken; do not pick The CRA plan is strategy or Window dressing yet.

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 notice that cites 'other' as the principal reason 40% of the time. 3. Flag any disparate-impact table second-review underwriter cannot explain from geographic application and origination heat map. 4. For this Fair Lending Redlining and HMDA Data file, read geographic application and origination heat map 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 second-review underwriter.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / Redlining and HMDA Data packet (geographic application and origination heat map after a notice that cites 'other' as the principal reason 40% of the time). The follow-on Redlining and HMDA Data action is what second-review underwriter 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 geographic application and origination heat map, then the action for second-review underwriter - Hypothesis scorecard against geographic application and origination heat map: supported / rejected / untestable - Missing page in geographic application and origination heat map after a notice that cites 'other' as the principal reason 40% of the time, if any - Regulatory or exam hook Redlining and HMDA Data would cite