Assess whether the CRA plan is strategy or window dressing (40806c)

SITUATION Exam-response coordinator is responsible for the CRA plan is in a bank, using thin HMDA LAR quality with mortgage pricing residual by prohibited-basis group as the only working extract. A vendor score change with no disparate-impact test is what reset the timeline for this Fair Lending Redlining and HMDA Data file.

DECISION Exam-response coordinator in a bank with thin HMDA LAR quality must choose The CRA plan is strategy / Window dressing using mortgage pricing residual by prohibited-basis group after a vendor score change with no disparate-impact test.

HYPOTHESES TO TEST 1. Authorize The CRA plan is strategy now; mortgage pricing residual by prohibited-basis group already has the discriminator after a vendor score change with no disparate-impact test. 2. Keep Window dressing in force until mortgage pricing residual by prohibited-basis group is completed after a vendor score change with no disparate-impact test for exam-response coordinator. 3. Treat mortgage pricing residual by prohibited-basis group 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 mortgage pricing residual by prohibited-basis group.

ANALYSIS REQUIRED 1. Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a vendor score change with no disparate-impact test. 2. Flag any disparate-impact table exam-response coordinator cannot explain from mortgage pricing residual by prohibited-basis group. 3. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 4. For this Fair Lending Redlining and HMDA Data file, read mortgage pricing residual by prohibited-basis group 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 / Redlining and HMDA Data packet (mortgage pricing residual by prohibited-basis group after a vendor score change with no disparate-impact test). The follow-on Redlining and HMDA Data 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 mortgage pricing residual by prohibited-basis group, then the action for exam-response coordinator - Hypothesis scorecard against mortgage pricing residual by prohibited-basis group: supported / rejected / untestable - Owner and next date for exam-response coordinator in a bank with thin HMDA LAR quality - What changes the CRA plan is if a vendor score change with no disparate-impact test is later withdrawn