Assess whether the CRA plan is strategy or window dressing after a board

SITUATION Second-review underwriter in a small-business desk using a new vendor score has one working extract — geographic application and origination heat map — after a board asking if the bank should settle a matched-pair study. If geographic application and origination heat map cannot support the CRA plan is, the only defensible Fair Lending output is hold.

DECISION Second-review underwriter in a small-business desk using a new vendor score must choose The CRA plan is strategy / Window dressing using geographic application and origination heat map after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. Authorize The CRA plan is strategy now; geographic application and origination heat map already has the discriminator after a board asking if the bank should settle a matched-pair study. 2. Keep Window dressing in force until geographic application and origination heat map is completed after a board asking if the bank should settle a matched-pair study for second-review underwriter. 3. Treat geographic application and origination heat map as The CRA plan is strategy because both readings appear after a board asking if the bank should settle a matched-pair study. 4. Refuse a Fair Lending close: second-review underwriter does not have the decision the CRA plan is turns on in geographic application and origination heat map.

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 board asking if the bank should settle a matched-pair study. 4. For this Fair Lending Redlining and HMDA Data file, read geographic application and origination heat map 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 second-review underwriter.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / Redlining and HMDA Data packet (geographic application and origination heat map after a board asking if the bank should settle a matched-pair study). The follow-on Redlining and HMDA Data action is what second-review underwriter does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on the CRA plan is, then the evidence in geographic application and origination heat map, then the action for second-review underwriter - Hypothesis scorecard against geographic application and origination heat map: supported / rejected / untestable - Redlining and HMDA Data finding in geographic application and origination heat map that a second reviewer can re-perform - Missing page in geographic application and origination heat map after a board asking if the bank should settle a matched-pair study, if any