Assess whether the CRA plan is strategy or window dressing (a0c165)

SITUATION In a lender expanding into majority-minority census tracts, geographic application and origination heat map is the evidence after a marketing mailer that skipped majority-minority tracts. Model-risk partner for credit scoring has to pick The CRA plan is strategy or Window dressing for this Fair Lending Examination and Notices close using geographic application and origination heat map.

DECISION Model-risk partner for credit scoring in a lender expanding into majority-minority census tracts must choose The CRA plan is strategy / Window dressing using geographic application and origination heat map 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 Examination and Notices process in a lender expanding into majority-minority census tracts, given geographic application and origination heat map. 2. A marketing mailer that skipped majority-minority tracts is the event in geographic application and origination heat map that forces The CRA plan is strategy for model-risk partner for credit scoring under Fair Lending. 3. Geographic application and origination heat map shows a one-file miss after a marketing mailer that skipped majority-minority tracts, not a Examination and Notices program failure. 4. Geographic application and origination heat map cannot decide the CRA plan is yet after a marketing mailer that skipped majority-minority tracts; hold is the only Fair Lending close a lender expanding into majority-minority census tracts can defend.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in geographic application and origination heat map. 2. Check HMDA coding and underwriting policy against the CRA plan is. 3. Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts. 4. For this Fair Lending Examination and Notices file, read geographic application and origination heat map against a marketing mailer that skipped majority-minority tracts and write the one fact that would move the CRA plan is for model-risk partner for credit scoring.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / Examination and Notices packet (geographic application and origination heat map after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option geographic application and origination heat map can support after a marketing mailer that skipped majority-minority tracts, then the two facts that force it, then the Monday action for model-risk partner for credit scoring in a lender expanding into majority-minority census tracts.