Assess whether the CRA plan is strategy or window dressing (49b701)

SITUATION After a CRA PE that called the assessment area too narrow, appraisal-gap outcomes in majority-minority tracts is what exam-response coordinator can touch in a mortgage company after a pricing-regression spike. Fair Lending will live with The CRA plan is strategy versus Window dressing on this Examination and Notices file.

DECISION Exam-response coordinator in a mortgage company after a pricing-regression spike must choose The CRA plan is strategy / Window dressing using appraisal-gap outcomes in majority-minority tracts after a CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. A CRA PE that called the assessment area too narrow is noise around an already-controlled Examination and Notices process in a mortgage company after a pricing-regression spike, given appraisal-gap outcomes in majority-minority tracts. 2. A CRA PE that called the assessment area too narrow is the event in appraisal-gap outcomes in majority-minority tracts that forces The CRA plan is strategy for exam-response coordinator under Fair Lending. 3. Appraisal-gap outcomes in majority-minority tracts shows a one-file miss after a CRA PE that called the assessment area too narrow, not a Examination and Notices program failure. 4. Appraisal-gap outcomes in majority-minority tracts cannot decide the CRA plan is yet after a CRA PE that called the assessment area too narrow; hold is the only Fair Lending close a mortgage company after a pricing-regression spike can defend.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the CRA plan is. 2. Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow. 3. Flag any disparate-impact table exam-response coordinator cannot explain from appraisal-gap outcomes in majority-minority tracts. 4. For this Fair Lending Examination and Notices file, read appraisal-gap outcomes in majority-minority tracts against a CRA PE that called the assessment area too narrow and write the one fact that would move the CRA plan is for exam-response coordinator.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / Examination and Notices packet (appraisal-gap outcomes in majority-minority tracts after a CRA PE that called the assessment area too narrow). The follow-on Examination and Notices action is what exam-response coordinator 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 appraisal-gap outcomes in majority-minority tracts, then the action for exam-response coordinator - Hypothesis scorecard against appraisal-gap outcomes in majority-minority tracts: supported / rejected / untestable - What changes the CRA plan is if a CRA PE that called the assessment area too narrow is later withdrawn - Named option among The CRA plan is strategy, Window dressing and the fact that kills the others