Assess whether the CRA plan is strategy or window dressing (9737f2)

SITUATION After an underwriter chat that used coded language, HMDA LAR validity and quality edits is what model-risk partner for credit scoring can touch in a credit-card issuer changing line-assignment logic. Fair Lending will live with The CRA plan is strategy versus Window dressing on this CRA and Special-Purpose Programs file.

DECISION Model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic must choose The CRA plan is strategy / Window dressing using HMDA LAR validity and quality edits after an underwriter chat that used coded language.

HYPOTHESES TO TEST 1. An underwriter chat that used coded language is noise around an already-controlled CRA and Special-Purpose Programs process in a credit-card issuer changing line-assignment logic, given HMDA LAR validity and quality edits. 2. An underwriter chat that used coded language 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 an underwriter chat that used coded language, not a CRA and Special-Purpose Programs program failure. 4. HMDA LAR validity and quality edits cannot decide the CRA plan is yet after an underwriter chat that used coded language; hold is the only Fair Lending close a credit-card issuer changing line-assignment logic can defend.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic 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 CRA and Special-Purpose Programs file, read HMDA LAR validity and quality edits against an underwriter chat that used coded language 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 / CRA and Special-Purpose Programs packet (HMDA LAR validity and quality edits after an underwriter chat that used coded language). The follow-on CRA and Special-Purpose Programs 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 - Regulatory or exam hook CRA and Special-Purpose Programs would cite - CRA and Special-Purpose Programs finding in HMDA LAR validity and quality edits that a second reviewer can re-perform