Assess whether the CRA plan is strategy or window dressing (9d5be9)

SITUATION Exam-response coordinator in a manufactured-housing lender with dealer-originated files has one working extract — appraisal-gap outcomes in majority-minority tracts — after an exception rate twice as high for one group after credit controls. Exam-response coordinator in a manufactured-housing lender with dealer-originated files has appraisal-gap outcomes in majority-minority tracts after an exception rate twice as high for one group after credit controls. If that extract cannot support the CRA plan is, the only defensible Fair Lending CRA and Special-Purpose Programs output is hold.

DECISION Exam-response coordinator in a manufactured-housing lender with dealer-originated files must choose The CRA plan is strategy / Window dressing using appraisal-gap outcomes in majority-minority tracts after an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. The population in appraisal-gap outcomes in majority-minority tracts is the one an exception rate twice as high for one group after credit controls named, so The CRA plan is strategy follows for this CRA and Special-Purpose Programs file. 2. The population in appraisal-gap outcomes in majority-minority tracts is adjacent only to an exception rate twice as high for one group after credit controls; Window dressing is the honest Fair Lending call. 3. A manufactured-housing lender with dealer-originated files already contained an exception rate twice as high for one group after credit controls before appraisal-gap outcomes in majority-minority tracts arrived; no new CRA and Special-Purpose Programs path. 4. Provenance on appraisal-gap outcomes in majority-minority tracts after an exception rate twice as high for one group after credit controls is broken; do not pick The CRA plan is strategy or Window dressing yet.

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 an exception rate twice as high for one group after credit controls. 3. Flag any disparate-impact table exam-response coordinator cannot explain from appraisal-gap outcomes in majority-minority tracts. 4. For this Fair Lending CRA and Special-Purpose Programs file, read appraisal-gap outcomes in majority-minority tracts 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 exam-response coordinator.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / CRA and Special-Purpose Programs packet (appraisal-gap outcomes in majority-minority tracts after an exception rate twice as high for one group after credit controls). If appraisal-gap outcomes in majority-minority tracts cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If appraisal-gap outcomes in majority-minority tracts after an exception rate twice as high for one group after credit controls cannot support The CRA plan is strategy versus Window dressing on this Fair Lending CRA and Special-Purpose Programs close, exam-response coordinator must do not infer a control or scheme beyond the transaction and entitlement evidence.