Whether the CRA plan is strategy or window dressing from CRA assessment-area

Situation

A board asking if the bank should settle a matched-pair study put CRA assessment-area versus lending footprint in front of HMDA data-quality manager in a lender expanding into majority-minority census tracts. This Fair Lending / Pricing and Credit Limits close is the CRA plan is from CRA assessment-area versus lending footprint, and the live options are The CRA plan is strategy, Window dressing.

Decision

HMDA data-quality manager in a lender expanding into majority-minority census tracts must choose The CRA plan is strategy / Window dressing using CRA assessment-area versus lending footprint after a board asking if the bank should settle a matched-pair study.

Hypotheses to test

• The population in CRA assessment-area versus lending footprint is the one a board asking if the bank should settle a matched-pair study named, so The CRA plan is strategy follows for this Pricing and Credit Limits file.
• The population in CRA assessment-area versus lending footprint is adjacent only to a board asking if the bank should settle a matched-pair study; Window dressing is the honest Fair Lending call.
• A lender expanding into majority-minority census tracts already contained a board asking if the bank should settle a matched-pair study before CRA assessment-area versus lending footprint arrived; no new Pricing and Credit Limits path.
• Provenance on CRA assessment-area versus lending footprint after a board asking if the bank should settle a matched-pair study is broken; do not pick The CRA plan is strategy or Window dressing yet.

Analysis required

• Match the adverse-action language to the facts in CRA assessment-area versus lending footprint.
• Check HMDA coding and underwriting policy against the CRA plan is.
• Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study.
• For this Fair Lending Pricing and Credit Limits file, read CRA assessment-area versus lending footprint 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 HMDA data-quality manager.

Recommendation

Choose The CRA plan is strategy / Window dressing on this Fair Lending / Pricing and Credit Limits packet (CRA assessment-area versus lending footprint after a board asking if the bank should settle a matched-pair study). The follow-on Pricing and Credit Limits action is what HMDA data-quality manager does next: implement the option, assign an owner, and log the missing fact.