Assess whether the CRA plan is strategy or window dressing (f52860)

SITUATION In a credit-card issuer changing line-assignment logic, manufactured-housing dealer overlay notes is the evidence after a vendor score change with no disparate-impact test. Adverse-action notice operations lead has to pick The CRA plan is strategy or Window dressing for this Fair Lending Examination and Notices close using manufactured-housing dealer overlay notes.

DECISION Adverse-action notice operations lead in a credit-card issuer changing line-assignment logic must choose The CRA plan is strategy / Window dressing using manufactured-housing dealer overlay notes after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. Authorize The CRA plan is strategy now; manufactured-housing dealer overlay notes already has the discriminator after a vendor score change with no disparate-impact test. 2. Keep Window dressing in force until manufactured-housing dealer overlay notes is completed after a vendor score change with no disparate-impact test for adverse-action notice operations lead. 3. Treat manufactured-housing dealer overlay notes as The CRA plan is strategy because both readings appear after a vendor score change with no disparate-impact test. 4. Refuse a Fair Lending close: adverse-action notice operations lead does not have the decision the CRA plan is turns on in manufactured-housing dealer overlay notes.

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 manufactured-housing dealer overlay notes. 3. Check HMDA coding and underwriting policy against the CRA plan is. 4. For this Fair Lending Examination and Notices file, read manufactured-housing dealer overlay notes against a vendor score change with no disparate-impact test and write the one fact that would move the CRA plan is for adverse-action notice operations lead.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / Examination and Notices packet (manufactured-housing dealer overlay notes after a vendor score change with no disparate-impact test). The follow-on Examination and Notices action is what adverse-action notice operations lead 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 manufactured-housing dealer overlay notes, then the action for adverse-action notice operations lead - Hypothesis scorecard against manufactured-housing dealer overlay notes: supported / rejected / untestable - What changes the CRA plan is if a vendor score change with no disparate-impact test is later withdrawn - Named option among The CRA plan is strategy, Window dressing and the fact that kills the others