Assess whether the CRA plan is strategy or window dressing (eb5b56)

SITUATION CRA and Special-Purpose Programs work in a small-business desk using a new vendor score now turns on the CRA plan is because a board asking if the bank should settle a matched-pair study put mortgage pricing residual by prohibited-basis group in play. Adverse-action notice operations lead should say what mortgage pricing residual by prohibited-basis group proves.

DECISION Adverse-action notice operations lead in a small-business desk using a new vendor score must choose The CRA plan is strategy / Window dressing using mortgage pricing residual by prohibited-basis group after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. A board asking if the bank should settle a matched-pair study is noise around an already-controlled CRA and Special-Purpose Programs process in a small-business desk using a new vendor score, given mortgage pricing residual by prohibited-basis group. 2. A board asking if the bank should settle a matched-pair study is the event in mortgage pricing residual by prohibited-basis group that forces The CRA plan is strategy for adverse-action notice operations lead under Fair Lending. 3. Mortgage pricing residual by prohibited-basis group shows a one-file miss after a board asking if the bank should settle a matched-pair study, not a CRA and Special-Purpose Programs program failure. 4. Mortgage pricing residual by prohibited-basis group cannot decide the CRA plan is yet after a board asking if the bank should settle a matched-pair study; hold is the only Fair Lending close a small-business desk using a new vendor score can defend.

ANALYSIS REQUIRED 1. Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study. 2. Flag any disparate-impact table adverse-action notice operations lead cannot explain from mortgage pricing residual by prohibited-basis group. 3. Test a documented exception versus a pattern a small-business desk using a new vendor score must defend. 4. For this Fair Lending CRA and Special-Purpose Programs file, read mortgage pricing residual by prohibited-basis group against a board asking if the bank should settle a matched-pair study and write the one fact that would move the CRA plan is for adverse-action notice operations lead.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / CRA and Special-Purpose Programs packet (mortgage pricing residual by prohibited-basis group after a board asking if the bank should settle a matched-pair study). Lead with the Fair Lending option mortgage pricing residual by prohibited-basis group can support after a board asking if the bank should settle a matched-pair study, then the two facts that force it, then the Monday action for adverse-action notice operations lead in a small-business desk using a new vendor score.