Assess whether the CRA plan is strategy or window dressing (d52323)

SITUATION After a SPCP that originated almost no loans to the intended class, HMDA LAR validity and quality edits is what second-review underwriter can touch in a credit union rolling out a special-purpose credit program. Fair Lending will live with The CRA plan is strategy versus Window dressing on this Examination and Notices file.

DECISION Second-review underwriter 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 SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. A SPCP that originated almost no loans to the intended class is noise around an already-controlled Examination and Notices process in a credit union rolling out a special-purpose credit program, given HMDA LAR validity and quality edits. 2. A SPCP that originated almost no loans to the intended class is the event in HMDA LAR validity and quality edits that forces The CRA plan is strategy for second-review underwriter under Fair Lending. 3. HMDA LAR validity and quality edits shows a one-file miss after a SPCP that originated almost no loans to the intended class, not a Examination and Notices program failure. 4. HMDA LAR validity and quality edits cannot decide the CRA plan is yet after a SPCP that originated almost no loans to the intended class; hold is the only Fair Lending close a credit union rolling out a special-purpose credit program can defend.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the CRA plan is. 2. Compare HMDA LAR validity and quality edits 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 second-review underwriter cannot explain from HMDA LAR validity and quality edits. 4. For this Fair Lending Examination and Notices file, read HMDA LAR validity and quality edits 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 second-review underwriter.

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 SPCP that originated almost no loans to the intended class). If HMDA LAR validity and quality edits cannot force a Fair Lending label under Examination and Notices, stop. Do not invent missing evidence a credit union rolling out a special-purpose credit program does not have.

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 second-review underwriter - Hypothesis scorecard against HMDA LAR validity and quality edits: supported / rejected / untestable - Named option among The CRA plan is strategy, Window dressing and the fact that kills the others - Owner and next date for second-review underwriter in a credit union rolling out a special-purpose credit program