Assess whether the CRA plan is strategy or window dressing (b8db7e)

SITUATION Appraisal-gap outcomes in majority-minority tracts arrived with a HMDA resubmission that still fails quality edits for second-review underwriter. That is a Fair Lending Redlining and HMDA Data decision on the CRA plan is in a small-business desk using a new vendor score.

DECISION Second-review underwriter in a small-business desk using a new vendor score must choose The CRA plan is strategy / Window dressing using appraisal-gap outcomes in majority-minority tracts after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. Second-review underwriter can defend The CRA plan is strategy from appraisal-gap outcomes in majority-minority tracts after a HMDA resubmission that still fails quality edits in a Fair Lending challenge. 2. Second-review underwriter cannot defend The CRA plan is strategy from appraisal-gap outcomes in majority-minority tracts; Window dressing is what the extract actually supports after a HMDA resubmission that still fails quality edits. 3. A HMDA resubmission that still fails quality edits 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 a HMDA resubmission that still fails quality edits conflict for second-review underwriter; hold this Redlining and HMDA Data file.

ANALYSIS REQUIRED 1. Flag any disparate-impact table second-review underwriter cannot explain from appraisal-gap outcomes in majority-minority tracts. 2. Test a documented exception versus a pattern a small-business desk using a new vendor score must defend. 3. Match the adverse-action language to the facts in appraisal-gap outcomes in majority-minority tracts. 4. For this Fair Lending Redlining and HMDA Data file, read appraisal-gap outcomes in majority-minority tracts against a HMDA resubmission that still fails quality edits and write the one fact that would move the CRA plan is for second-review underwriter.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / Redlining and HMDA Data packet (appraisal-gap outcomes in majority-minority tracts after a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option appraisal-gap outcomes in majority-minority tracts can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for second-review underwriter in a small-business desk using a new vendor score.

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 second-review underwriter - Hypothesis scorecard against appraisal-gap outcomes in majority-minority tracts: supported / rejected / untestable - Named option among The CRA plan is strategy, Window dressing and the fact that kills the others - Owner and next date for second-review underwriter in a small-business desk using a new vendor score