Adverse-action notice operations lead must resolve whether the CRA plan

Situation

The CRA plan is sits with adverse-action notice operations lead because a DOJ or CFPB monitor request for pricing files hit a credit union rolling out a special-purpose credit program. Evidence is appraisal-gap outcomes in majority-minority tracts; write the Fair Lending Pricing and Credit Limits option that extract can carry.

Decision

Adverse-action notice operations lead in a credit union rolling out a special-purpose credit program must choose The CRA plan is strategy / Window dressing using appraisal-gap outcomes in majority-minority tracts after a DOJ or CFPB monitor request for pricing files.

Hypotheses to test

• Appraisal-gap outcomes in majority-minority tracts reads as The CRA plan is strategy once a DOJ or CFPB monitor request for pricing files is lined up to the same Fair Lending population.
• Appraisal-gap outcomes in majority-minority tracts is closer to Window dressing after a DOJ or CFPB monitor request for pricing files; The CRA plan is strategy would over-claim this Pricing and Credit Limits extract.
• A dual reading is still live in appraisal-gap outcomes in majority-minority tracts for adverse-action notice operations lead in a credit union rolling out a special-purpose credit program.
• Appraisal-gap outcomes in majority-minority tracts is missing the fact adverse-action notice operations lead needs after a DOJ or CFPB monitor request for pricing files; stop this Fair Lending close.

Analysis required

• Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts.
• Check HMDA coding and underwriting policy against the CRA plan is.
• Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files.
• For this Fair Lending Pricing and Credit Limits file, read appraisal-gap outcomes in majority-minority tracts against a DOJ or CFPB monitor request for pricing files 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 / Pricing and Credit Limits packet (appraisal-gap outcomes in majority-minority tracts after a DOJ or CFPB monitor request for pricing files). The follow-on Pricing and Credit Limits action is what adverse-action notice operations lead does next: implement the option, assign an owner, and log the missing fact.