Assess whether the CRA plan is strategy or window dressing (1684fa)

SITUATION In a credit-card issuer changing line-assignment logic, small-business decline comparative file set is the evidence after a HMDA resubmission that still fails quality edits. HMDA data-quality manager has to pick The CRA plan is strategy or Window dressing for this Fair Lending Redlining and HMDA Data close using small-business decline comparative file set.

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 a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. The population in small-business decline comparative file set is the one a HMDA resubmission that still fails quality edits named, so The CRA plan is strategy follows for this Redlining and HMDA Data file. 2. The population in small-business decline comparative file set is adjacent only to a HMDA resubmission that still fails quality edits; Window dressing is the honest Fair Lending call. 3. A credit-card issuer changing line-assignment logic already contained a HMDA resubmission that still fails quality edits before small-business decline comparative file set arrived; no new Redlining and HMDA Data path. 4. Provenance on small-business decline comparative file set after a HMDA resubmission that still fails quality edits is broken; do not pick The CRA plan is strategy or Window dressing yet.

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 small-business decline comparative file set. 3. Check HMDA coding and underwriting policy against the CRA plan is. 4. For this Fair Lending Redlining and HMDA Data file, read small-business decline comparative file set against a HMDA resubmission that still fails quality edits 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 a HMDA resubmission that still fails quality edits). 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 - Owner and next date for HMDA data-quality manager in a credit-card issuer changing line-assignment logic - What changes the CRA plan is if a HMDA resubmission that still fails quality edits is later withdrawn