Assess whether the CRA plan is strategy or window dressing (b5fb51)

SITUATION Model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program has one working extract — HMDA LAR validity and quality edits — after a marketing mailer that skipped majority-minority tracts. If HMDA LAR validity and quality edits cannot support the CRA plan is, the only defensible Fair Lending output is hold.

DECISION Model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program must choose The CRA plan is strategy / Window dressing using HMDA LAR validity and quality edits after a marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. The population in HMDA LAR validity and quality edits is the one a marketing mailer that skipped majority-minority tracts named, so The CRA plan is strategy follows for this Redlining and HMDA Data file. 2. The population in HMDA LAR validity and quality edits is adjacent only to a marketing mailer that skipped majority-minority tracts; Window dressing is the honest Fair Lending call. 3. A credit union rolling out a special-purpose credit program already contained a marketing mailer that skipped majority-minority tracts before HMDA LAR validity and quality edits arrived; no new Redlining and HMDA Data path. 4. Provenance on HMDA LAR validity and quality edits after a marketing mailer that skipped majority-minority tracts is broken; do not pick The CRA plan is strategy or Window dressing yet.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a credit union rolling out a special-purpose credit program must defend. 2. Match the adverse-action language to the facts in HMDA LAR validity and quality edits. 3. Check HMDA coding and underwriting policy against the CRA plan is. 4. For this Fair Lending Redlining and HMDA Data file, read HMDA LAR validity and quality edits against a marketing mailer that skipped majority-minority tracts 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 / Redlining and HMDA Data packet (HMDA LAR validity and quality edits after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option HMDA LAR validity and quality edits can support after a marketing mailer that skipped majority-minority tracts, then the two facts that force it, then the Monday action for model-risk partner for credit scoring in a credit union rolling out a special-purpose credit program.

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 - Regulatory or exam hook Redlining and HMDA Data would cite - Redlining and HMDA Data finding in HMDA LAR validity and quality edits that a second reviewer can re-perform