Assess whether the CRA plan is strategy or window dressing (86bbce)

SITUATION Community-development lender in a mortgage company after a pricing-regression spike has one working extract — manufactured-housing dealer overlay notes — after a notice that cites 'other' as the principal reason 40% of the time. If manufactured-housing dealer overlay notes cannot support the CRA plan is, the only defensible Fair Lending output is hold.

DECISION Community-development lender in a mortgage company after a pricing-regression spike must choose The CRA plan is strategy / Window dressing using manufactured-housing dealer overlay notes after a notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. Community-development lender can defend The CRA plan is strategy from manufactured-housing dealer overlay notes after a notice that cites 'other' as the principal reason 40% of the time in a Fair Lending challenge. 2. Community-development lender cannot defend The CRA plan is strategy from manufactured-housing dealer overlay notes; Window dressing is what the extract actually supports after a notice that cites 'other' as the principal reason 40% of the time. 3. A notice that cites 'other' as the principal reason 40% of the time never reached the population in manufactured-housing dealer overlay notes — reopen intake, do not close the CRA plan is. 4. Two facts in manufactured-housing dealer overlay notes after a notice that cites 'other' as the principal reason 40% of the time conflict for community-development lender; hold this Redlining and HMDA Data file.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the CRA plan is. 2. Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time. 3. Flag any disparate-impact table community-development lender cannot explain from manufactured-housing dealer overlay notes. 4. For this Fair Lending Redlining and HMDA Data file, read manufactured-housing dealer overlay notes against a notice that cites 'other' as the principal reason 40% of the time 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 / Redlining and HMDA Data packet (manufactured-housing dealer overlay notes after a notice that cites 'other' as the principal reason 40% of the time). If manufactured-housing dealer overlay notes cannot force a Fair Lending label under Redlining and HMDA Data, stop. If manufactured-housing dealer overlay notes after a notice that cites 'other' as the principal reason 40% of the time cannot support The CRA plan is strategy versus Window dressing on this Fair Lending Redlining and HMDA Data close, community-development lender must do not infer a control or scheme beyond the transaction and entitlement evidence.