Assess whether the CRA plan is strategy or window dressing (41676d)

SITUATION Small-business decline comparative file set arrived with a vendor score change with no disparate-impact test for model-risk partner for credit scoring. That is a Fair Lending CRA and Special-Purpose Programs decision on the CRA plan is in a credit-card issuer changing line-assignment logic.

DECISION Model-risk partner for credit scoring 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 vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. Authorize The CRA plan is strategy now; small-business decline comparative file set already has the discriminator after a vendor score change with no disparate-impact test. 2. Keep Window dressing in force until small-business decline comparative file set is completed after a vendor score change with no disparate-impact test for model-risk partner for credit scoring. 3. Treat small-business decline comparative file set 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: model-risk partner for credit scoring does not have the decision the CRA plan is turns on in small-business decline comparative file set.

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 CRA and Special-Purpose Programs file, read small-business decline comparative file set against a vendor score change with no disparate-impact test and write the one fact that would move the CRA plan is for model-risk partner for credit scoring.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / CRA and Special-Purpose Programs packet (small-business decline comparative file set after a vendor score change with no disparate-impact test). The follow-on CRA and Special-Purpose Programs action is what model-risk partner for credit scoring 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 model-risk partner for credit scoring - Hypothesis scorecard against small-business decline comparative file set: supported / rejected / untestable - Named option among The CRA plan is strategy, Window dressing and the fact that kills the others - Owner and next date for model-risk partner for credit scoring in a credit-card issuer changing line-assignment logic