Community-development lender must resolve whether the CRA plan is strategy

Situation

Pricing and Credit Limits work in a bank with thin HMDA LAR quality now turns on the CRA plan is because an exception rate twice as high for one group after credit controls put CRA assessment-area versus lending footprint in play. Community-development lender should say what CRA assessment-area versus lending footprint proves.

Decision

Community-development lender in a bank with thin HMDA LAR quality must choose The CRA plan is strategy / Window dressing using CRA assessment-area versus lending footprint after an exception rate twice as high for one group after credit controls.

Hypotheses to test

• Authorize The CRA plan is strategy now; CRA assessment-area versus lending footprint already has the discriminator after an exception rate twice as high for one group after credit controls.
• Keep Window dressing in force until CRA assessment-area versus lending footprint is completed after an exception rate twice as high for one group after credit controls for community-development lender.
• Treat CRA assessment-area versus lending footprint as The CRA plan is strategy because both readings appear after an exception rate twice as high for one group after credit controls.
• Refuse a Fair Lending close: community-development lender does not have the page the CRA plan is turns on in CRA assessment-area versus lending footprint.

Analysis required

• Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend.
• 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.
• For this Fair Lending Pricing and Credit Limits file, read CRA assessment-area versus lending footprint against an exception rate twice as high for one group after credit controls 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 / Pricing and Credit Limits packet (CRA assessment-area versus lending footprint after an exception rate twice as high for one group after credit controls). If CRA assessment-area versus lending footprint cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent pages a bank with thin HMDA LAR quality does not have.