Assess whether the CRA plan is strategy or window dressing (624f71)

SITUATION After a HMDA resubmission that still fails quality edits, mortgage pricing residual by prohibited-basis group is what exam-response coordinator 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 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 HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. Authorize The CRA plan is strategy now; mortgage pricing residual by prohibited-basis group already has the discriminator after a HMDA resubmission that still fails quality edits. 2. Keep Window dressing in force until mortgage pricing residual by prohibited-basis group is completed after a HMDA resubmission that still fails quality edits 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 HMDA resubmission that still fails quality edits. 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 HMDA resubmission that still fails quality edits. 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 HMDA resubmission that still fails quality edits 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 HMDA resubmission that still fails quality edits). 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 - Redlining and HMDA Data finding in mortgage pricing residual by prohibited-basis group that a second reviewer can re-perform - Missing page in mortgage pricing residual by prohibited-basis group after a HMDA resubmission that still fails quality edits, if any