Assess whether the CRA plan is strategy or window dressing (0c3aa0)

SITUATION A lender expanding into majority-minority census tracts has SPCP written plan versus actual originations in hand following an exception rate twice as high for one group after credit controls. Model-risk partner for credit scoring must determine whether the CRA plan is strategy or window dressing for this Fair Lending Examination and Notices file.

DECISION Model-risk partner for credit scoring in a lender expanding into majority-minority census tracts must choose The CRA plan is strategy / Window dressing using SPCP written plan versus actual originations after an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. Model-risk partner for credit scoring can defend The CRA plan is strategy from SPCP written plan versus actual originations after an exception rate twice as high for one group after credit controls in a Fair Lending challenge. 2. Model-risk partner for credit scoring cannot defend The CRA plan is strategy from SPCP written plan versus actual originations; Window dressing is what the extract actually supports after an exception rate twice as high for one group after credit controls. 3. An exception rate twice as high for one group after credit controls never reached the population in SPCP written plan versus actual originations — reopen intake, do not close the CRA plan is. 4. Two facts in SPCP written plan versus actual originations after an exception rate twice as high for one group after credit controls conflict for model-risk partner for credit scoring; hold this Examination and Notices file.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in SPCP written plan versus actual originations. 2. Check HMDA coding and underwriting policy against the CRA plan is. 3. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls. 4. For this Fair Lending Examination and Notices file, read SPCP written plan versus actual originations against an exception rate twice as high for one group after credit controls 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 / Examination and Notices packet (SPCP written plan versus actual originations after an exception rate twice as high for one group after credit controls). The follow-on Examination and Notices 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 SPCP written plan versus actual originations, then the action for model-risk partner for credit scoring - Hypothesis scorecard against SPCP written plan versus actual originations: supported / rejected / untestable - Missing page in SPCP written plan versus actual originations after an exception rate twice as high for one group after credit controls, if any - Regulatory or exam hook Examination and Notices would cite