Assess whether the CRA plan is strategy or window dressing (ba6884)

SITUATION Exam-response coordinator in a manufactured-housing lender with dealer-originated files has one working extract — adverse-action notice principal-reason sample — after a DOJ or CFPB monitor request for pricing files. If adverse-action notice principal-reason sample cannot support the CRA plan is, the only defensible Fair Lending output is hold.

DECISION Exam-response coordinator in a manufactured-housing lender with dealer-originated files must choose The CRA plan is strategy / Window dressing using adverse-action notice principal-reason sample after a DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. The population in adverse-action notice principal-reason sample is the one a DOJ or CFPB monitor request for pricing files named, so The CRA plan is strategy follows for this CRA and Special-Purpose Programs file. 2. The population in adverse-action notice principal-reason sample is adjacent only to a DOJ or CFPB monitor request for pricing files; Window dressing is the honest Fair Lending call. 3. A manufactured-housing lender with dealer-originated files already contained a DOJ or CFPB monitor request for pricing files before adverse-action notice principal-reason sample arrived; no new CRA and Special-Purpose Programs path. 4. Provenance on adverse-action notice principal-reason sample after a DOJ or CFPB monitor request for pricing files is broken; do not pick The CRA plan is strategy or Window dressing yet.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the CRA plan is. 2. Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files. 3. Flag any disparate-impact table exam-response coordinator cannot explain from adverse-action notice principal-reason sample. 4. For this Fair Lending CRA and Special-Purpose Programs file, read adverse-action notice principal-reason sample against a DOJ or CFPB monitor request for pricing files 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 / CRA and Special-Purpose Programs packet (adverse-action notice principal-reason sample after a DOJ or CFPB monitor request for pricing files). Lead with the Fair Lending option adverse-action notice principal-reason sample can support after a DOJ or CFPB monitor request for pricing files, then the two facts that force it, then the Monday action for exam-response coordinator in a manufactured-housing lender with dealer-originated files.

COMMAND RETURNS - Bottom-line Fair Lending option on the CRA plan is, then the evidence in adverse-action notice principal-reason sample, then the action for exam-response coordinator - Hypothesis scorecard against adverse-action notice principal-reason sample: supported / rejected / untestable - Regulatory or exam hook CRA and Special-Purpose Programs would cite - CRA and Special-Purpose Programs finding in adverse-action notice principal-reason sample that a second reviewer can re-perform