Assess whether the CRA plan is strategy or window dressing (f1f895)

SITUATION Appraisal-gap outcomes in majority-minority tracts arrived with a vendor score change with no disparate-impact test for exam-response coordinator. That is a Fair Lending Examination and Notices decision on the CRA plan is in a mortgage company after a pricing-regression spike.

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 vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. Authorize The CRA plan is strategy now; appraisal-gap outcomes in majority-minority tracts already has the discriminator after a vendor score change with no disparate-impact test. 2. Keep Window dressing in force until appraisal-gap outcomes in majority-minority tracts is completed after a vendor score change with no disparate-impact test for exam-response coordinator. 3. Treat appraisal-gap outcomes in majority-minority tracts 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: exam-response coordinator does not have the decision the CRA plan is turns on in appraisal-gap outcomes in majority-minority tracts.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts. 2. Check HMDA coding and underwriting policy against the CRA plan is. 3. Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test. 4. For this Fair Lending Examination and Notices file, read appraisal-gap outcomes in majority-minority tracts against a vendor score change with no disparate-impact test 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 vendor score change with no disparate-impact test). 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 - Owner and next date for exam-response coordinator in a mortgage company after a pricing-regression spike - What changes the CRA plan is if a vendor score change with no disparate-impact test is later withdrawn