Assess whether the CRA plan is strategy or window dressing (54d733)

SITUATION The working file is SPCP written plan versus actual originations after a community complaint about appraisal gaps. Adverse-action notice operations lead in a credit-card issuer changing line-assignment logic has to name The CRA plan is strategy or Window dressing 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 SPCP written plan versus actual originations after a community complaint about appraisal gaps.

HYPOTHESES TO TEST 1. SPCP written plan versus actual originations reads as The CRA plan is strategy once a community complaint about appraisal gaps is lined up to the same Fair Lending population. 2. SPCP written plan versus actual originations is closer to Window dressing after a community complaint about appraisal gaps; The CRA plan is strategy would over-claim this Examination and Notices extract. 3. A dual reading is still live in SPCP written plan versus actual originations for adverse-action notice operations lead in a credit-card issuer changing line-assignment logic. 4. SPCP written plan versus actual originations is missing the fact adverse-action notice operations lead needs after a community complaint about appraisal gaps; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the CRA plan is. 2. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps. 3. Flag any disparate-impact table adverse-action notice operations lead cannot explain from SPCP written plan versus actual originations. 4. For this Fair Lending Examination and Notices file, read SPCP written plan versus actual originations against a community complaint about appraisal gaps 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 (SPCP written plan versus actual originations after a community complaint about appraisal gaps). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a community complaint about appraisal gaps, then the two facts that force it, then the Monday action for adverse-action notice operations lead in a credit-card issuer changing line-assignment logic.

COMMAND RETURNS - Bottom-line Fair Lending option on the CRA plan is, then the evidence in SPCP written plan versus actual originations, then the action for adverse-action notice operations lead - Hypothesis scorecard against SPCP written plan versus actual originations: 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 adverse-action notice operations lead in a credit-card issuer changing line-assignment logic