Assess whether the CRA plan is strategy or window dressing (c0edf7)

SITUATION After a branch that stopped taking applications in one ZIP, HMDA LAR validity and quality edits is what model-risk partner for credit scoring can touch in a lender expanding into majority-minority census tracts. Fair Lending will live with The CRA plan is strategy versus Window dressing on this Examination and Notices file.

DECISION Model-risk partner for credit scoring in a lender expanding into majority-minority census tracts must choose The CRA plan is strategy / Window dressing using HMDA LAR validity and quality edits after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. A branch that stopped taking applications in one ZIP is noise around an already-controlled Examination and Notices process in a lender expanding into majority-minority census tracts, given HMDA LAR validity and quality edits. 2. A branch that stopped taking applications in one ZIP is the event in HMDA LAR validity and quality edits that forces The CRA plan is strategy for model-risk partner for credit scoring under Fair Lending. 3. HMDA LAR validity and quality edits shows a one-file miss after a branch that stopped taking applications in one ZIP, not a Examination and Notices program failure. 4. HMDA LAR validity and quality edits cannot decide the CRA plan is yet after a branch that stopped taking applications in one ZIP; hold is the only Fair Lending close a lender expanding into majority-minority census tracts can defend.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in HMDA LAR validity and quality edits. 2. Check HMDA coding and underwriting policy against the CRA plan is. 3. Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP. 4. For this Fair Lending Examination and Notices file, read HMDA LAR validity and quality edits against a branch that stopped taking applications in one ZIP 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 / Examination and Notices packet (HMDA LAR validity and quality edits after a branch that stopped taking applications in one ZIP). The follow-on Examination and Notices 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 HMDA LAR validity and quality edits, then the action for model-risk partner for credit scoring - Hypothesis scorecard against HMDA LAR validity and quality edits: supported / rejected / untestable - Missing page in HMDA LAR validity and quality edits after a branch that stopped taking applications in one ZIP, if any - Regulatory or exam hook Examination and Notices would cite