Assess whether the CRA plan is strategy or window dressing (cf2305)

SITUATION The working file is small-business decline comparative file set after an underwriter chat that used coded language. HMDA data-quality manager in a credit-card issuer changing line-assignment logic has to name The CRA plan is strategy or Window dressing for this Fair Lending Redlining and HMDA Data file.

DECISION HMDA data-quality manager in a credit-card issuer changing line-assignment logic must choose The CRA plan is strategy / Window dressing using small-business decline comparative file set after an underwriter chat that used coded language.

HYPOTHESES TO TEST 1. Small-business decline comparative file set reads as The CRA plan is strategy once an underwriter chat that used coded language is lined up to the same Fair Lending population. 2. Small-business decline comparative file set is closer to Window dressing after an underwriter chat that used coded language; The CRA plan is strategy would over-claim this Redlining and HMDA Data extract. 3. A dual reading is still live in small-business decline comparative file set for HMDA data-quality manager in a credit-card issuer changing line-assignment logic. 4. Small-business decline comparative file set is missing the fact HMDA data-quality manager needs after an underwriter chat that used coded language; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after an underwriter chat that used coded language. 2. Flag any disparate-impact table HMDA data-quality manager cannot explain from small-business decline comparative file set. 3. Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend. 4. For this Fair Lending Redlining and HMDA Data file, read small-business decline comparative file set against an underwriter chat that used coded language and write the one fact that would move the CRA plan is for HMDA data-quality manager.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / Redlining and HMDA Data packet (small-business decline comparative file set after an underwriter chat that used coded language). The follow-on Redlining and HMDA Data action is what HMDA data-quality manager 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 small-business decline comparative file set, then the action for HMDA data-quality manager - Hypothesis scorecard against small-business decline comparative file set: supported / rejected / untestable - What changes the CRA plan is if an underwriter chat that used coded language is later withdrawn - Named option among The CRA plan is strategy, Window dressing and the fact that kills the others