Assess whether the CRA plan is strategy or window dressing (c474a1)

SITUATION After an underwriter chat that used coded language, appraisal-gap outcomes in majority-minority tracts is what fair-lending officer can touch in a bank with thin HMDA LAR quality. Fair Lending will live with The CRA plan is strategy versus Window dressing on this CRA and Special-Purpose Programs file.

DECISION Fair-lending officer in a bank with thin HMDA LAR quality must choose The CRA plan is strategy / Window dressing using appraisal-gap outcomes in majority-minority tracts after an underwriter chat that used coded language.

HYPOTHESES TO TEST 1. Fair-lending officer can defend The CRA plan is strategy from appraisal-gap outcomes in majority-minority tracts after an underwriter chat that used coded language in a Fair Lending challenge. 2. Fair-lending officer cannot defend The CRA plan is strategy from appraisal-gap outcomes in majority-minority tracts; Window dressing is what the extract actually supports after an underwriter chat that used coded language. 3. An underwriter chat that used coded language never reached the population in appraisal-gap outcomes in majority-minority tracts — reopen intake, do not close the CRA plan is. 4. Two facts in appraisal-gap outcomes in majority-minority tracts after an underwriter chat that used coded language conflict for fair-lending officer; hold this CRA and Special-Purpose Programs file.

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 an underwriter chat that used coded language. 4. For this Fair Lending CRA and Special-Purpose Programs file, read appraisal-gap outcomes in majority-minority tracts against an underwriter chat that used coded language and write the one fact that would move the CRA plan is for fair-lending officer.

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 underwriter chat that used coded language). The follow-on CRA and Special-Purpose Programs action is what fair-lending officer 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 fair-lending officer - Hypothesis scorecard against appraisal-gap outcomes in majority-minority tracts: supported / rejected / untestable - CRA and Special-Purpose Programs finding in appraisal-gap outcomes in majority-minority tracts that a second reviewer can re-perform - Missing page in appraisal-gap outcomes in majority-minority tracts after an underwriter chat that used coded language, if any