Assess whether the CRA plan is strategy or window dressing (7117e1)

SITUATION Community-development lender in an institution preparing for a redlining exam has one working extract — CRA assessment-area versus lending footprint — after a notice that cites 'other' as the principal reason 40% of the time. If CRA assessment-area versus lending footprint cannot support the CRA plan is, the only defensible Fair Lending output is hold.

DECISION Community-development lender in an institution preparing for a redlining exam must choose The CRA plan is strategy / Window dressing using CRA assessment-area versus lending footprint after a notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. Community-development lender can defend The CRA plan is strategy from CRA assessment-area versus lending footprint after a notice that cites 'other' as the principal reason 40% of the time in a Fair Lending challenge. 2. Community-development lender cannot defend The CRA plan is strategy from CRA assessment-area versus lending footprint; Window dressing is what the extract actually supports after a notice that cites 'other' as the principal reason 40% of the time. 3. A notice that cites 'other' as the principal reason 40% of the time never reached the population in CRA assessment-area versus lending footprint — reopen intake, do not close the CRA plan is. 4. Two facts in CRA assessment-area versus lending footprint after a notice that cites 'other' as the principal reason 40% of the time conflict for community-development lender; hold this CRA and Special-Purpose Programs file.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern an institution preparing for a redlining exam must defend. 2. Match the adverse-action language to the facts in CRA assessment-area versus lending footprint. 3. Check HMDA coding and underwriting policy against the CRA plan is. 4. For this Fair Lending CRA and Special-Purpose Programs file, read CRA assessment-area versus lending footprint against a notice that cites 'other' as the principal reason 40% of the time and write the one fact that would move the CRA plan is for community-development lender.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / CRA and Special-Purpose Programs packet (CRA assessment-area versus lending footprint after a notice that cites 'other' as the principal reason 40% of the time). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after a notice that cites 'other' as the principal reason 40% of the time, then the two facts that force it, then the Monday action for community-development lender in an institution preparing for a redlining exam.

COMMAND RETURNS - Bottom-line Fair Lending option on the CRA plan is, then the evidence in CRA assessment-area versus lending footprint, then the action for community-development lender - Hypothesis scorecard against CRA assessment-area versus lending footprint: supported / rejected / untestable - CRA and Special-Purpose Programs finding in CRA assessment-area versus lending footprint that a second reviewer can re-perform - Missing page in CRA assessment-area versus lending footprint after a notice that cites 'other' as the principal reason 40% of the time, if any