Assess whether the CRA plan is strategy or window dressing (112006)

SITUATION CRA and Special-Purpose Programs work in a small-business desk using a new vendor score now turns on the CRA plan is because an exception rate twice as high for one group after credit controls put manufactured-housing dealer overlay notes in play. Adverse-action notice operations lead should say what manufactured-housing dealer overlay notes proves.

DECISION Adverse-action notice operations lead in a small-business desk using a new vendor score must choose The CRA plan is strategy / Window dressing using manufactured-housing dealer overlay notes after an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. Authorize The CRA plan is strategy now; manufactured-housing dealer overlay notes already has the discriminator after an exception rate twice as high for one group after credit controls. 2. Keep Window dressing in force until manufactured-housing dealer overlay notes is completed after an exception rate twice as high for one group after credit controls for adverse-action notice operations lead. 3. Treat manufactured-housing dealer overlay notes as The CRA plan is strategy because both readings appear after an exception rate twice as high for one group after credit controls. 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. Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls. 2. Flag any disparate-impact table adverse-action notice operations lead cannot explain from manufactured-housing dealer overlay notes. 3. Test a documented exception versus a pattern a small-business desk using a new vendor score must defend. 4. For this Fair Lending CRA and Special-Purpose Programs file, read manufactured-housing dealer overlay notes against an exception rate twice as high for one group after credit controls 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 / CRA and Special-Purpose Programs packet (manufactured-housing dealer overlay notes after an exception rate twice as high for one group after credit controls). The follow-on CRA and Special-Purpose Programs 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 - CRA and Special-Purpose Programs finding in manufactured-housing dealer overlay notes that a second reviewer can re-perform - Missing page in manufactured-housing dealer overlay notes after an exception rate twice as high for one group after credit controls, if any