Assess whether the CRA plan is strategy or window dressing (3d8bae)

SITUATION Fair-lending officer at a manufactured-housing lender with dealer-originated files is reviewing CRA assessment-area versus lending footprint after a marketing mailer that skipped majority-minority tracts. The question on that extract is whether the CRA plan is strategy or window dressing. The packet does not yet prove The CRA plan is strategy versus Window dressing.

DECISION Fair-lending officer in a manufactured-housing lender with dealer-originated files must choose The CRA plan is strategy / Window dressing using CRA assessment-area versus lending footprint after a marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. A marketing mailer that skipped majority-minority tracts is noise around an already-controlled Redlining and HMDA Data process in a manufactured-housing lender with dealer-originated files, given CRA assessment-area versus lending footprint. 2. A marketing mailer that skipped majority-minority tracts is the event in CRA assessment-area versus lending footprint that forces The CRA plan is strategy for fair-lending officer under Fair Lending. 3. CRA assessment-area versus lending footprint shows a one-file miss after a marketing mailer that skipped majority-minority tracts, not a Redlining and HMDA Data program failure. 4. CRA assessment-area versus lending footprint cannot decide the CRA plan is yet after a marketing mailer that skipped majority-minority tracts; hold is the only Fair Lending close a manufactured-housing lender with dealer-originated files can defend.

ANALYSIS REQUIRED 1. Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts. 2. Flag any disparate-impact table fair-lending officer cannot explain from CRA assessment-area versus lending footprint. 3. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 4. For this Fair Lending Redlining and HMDA Data file, read CRA assessment-area versus lending footprint against a marketing mailer that skipped majority-minority tracts and write the one fact that would move the CRA plan is for fair-lending officer.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / Redlining and HMDA Data packet (CRA assessment-area versus lending footprint after a marketing mailer that skipped majority-minority tracts). If CRA assessment-area versus lending footprint cannot force a Fair Lending label under Redlining and HMDA Data, stop. If CRA assessment-area versus lending footprint after a marketing mailer that skipped majority-minority tracts cannot support The CRA plan is strategy versus Window dressing on this Fair Lending Redlining and HMDA Data close, fair-lending officer must do not infer a control or scheme beyond the transaction and entitlement evidence.