Assess whether the CRA plan is strategy or window dressing (37eeda)

SITUATION A SPCP that originated almost no loans to the intended class put CRA assessment-area versus lending footprint in front of CRA strategist in a bank with thin HMDA LAR quality. This Fair Lending / Examination and Notices decision 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 CRA strategist 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 a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. CRA strategist can defend The CRA plan is strategy from CRA assessment-area versus lending footprint after a SPCP that originated almost no loans to the intended class in a Fair Lending challenge. 2. CRA strategist cannot defend The CRA plan is strategy from CRA assessment-area versus lending footprint; Window dressing is what the extract actually supports after a SPCP that originated almost no loans to the intended class. 3. A SPCP that originated almost no loans to the intended class 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 SPCP that originated almost no loans to the intended class conflict for CRA strategist; hold this Examination and Notices file.

ANALYSIS REQUIRED 1. Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class. 2. Flag any disparate-impact table CRA strategist cannot explain from CRA assessment-area versus lending footprint. 3. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 4. For this Fair Lending Examination and Notices file, read CRA assessment-area versus lending footprint against a SPCP that originated almost no loans to the intended class and write the one fact that would move the CRA plan is for CRA strategist.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / Examination and Notices packet (CRA assessment-area versus lending footprint after a SPCP that originated almost no loans to the intended class). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after a SPCP that originated almost no loans to the intended class, then the two facts that force it, then the Monday action for CRA strategist in a bank with thin HMDA LAR quality.

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 CRA strategist - Hypothesis scorecard against CRA assessment-area versus lending footprint: supported / rejected / untestable - What changes the CRA plan is if a SPCP that originated almost no loans to the intended class is later withdrawn - Named option among The CRA plan is strategy, Window dressing and the fact that kills the others