Assess whether the CRA plan is strategy or window dressing (b4d8c7)

SITUATION Adverse-action notice operations lead is responsible for the CRA plan is in a credit-card issuer changing line-assignment logic, using model-reason-code mapping that does not match notices as the only working extract. A SPCP that originated almost no loans to the intended class is what reset the timeline for this Fair Lending Examination and Notices file.

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 model-reason-code mapping that does not match notices 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-card issuer changing line-assignment logic, given model-reason-code mapping that does not match notices. 2. A SPCP that originated almost no loans to the intended class is the event in model-reason-code mapping that does not match notices that forces The CRA plan is strategy for adverse-action notice operations lead under Fair Lending. 3. Model-reason-code mapping that does not match notices 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. Model-reason-code mapping that does not match notices 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-card issuer changing line-assignment logic can defend.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the CRA plan is. 2. Compare model-reason-code mapping that does not match notices 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 adverse-action notice operations lead cannot explain from model-reason-code mapping that does not match notices. 4. For this Fair Lending Examination and Notices file, read model-reason-code mapping that does not match notices 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 adverse-action notice operations lead.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / Examination and Notices packet (model-reason-code mapping that does not match notices after a SPCP that originated almost no loans to the intended class). 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.