Assess whether the CRA plan is strategy or window dressing (a82b29)

SITUATION Fair-lending officer in a bank with thin HMDA LAR quality has one working extract — model-reason-code mapping that does not match notices — after a DOJ or CFPB monitor request for pricing files. Fair-lending officer in a bank with thin HMDA LAR quality has model-reason-code mapping that does not match notices after a DOJ or CFPB monitor request for pricing files. If that extract cannot support the CRA plan is, the only defensible Fair Lending CRA and Special-Purpose Programs output is hold.

DECISION Fair-lending officer in a bank with thin HMDA LAR quality must choose The CRA plan is strategy / Window dressing using model-reason-code mapping that does not match notices after a DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. Model-reason-code mapping that does not match notices reads as The CRA plan is strategy once a DOJ or CFPB monitor request for pricing files is lined up to the same Fair Lending population. 2. Model-reason-code mapping that does not match notices is closer to Window dressing after a DOJ or CFPB monitor request for pricing files; The CRA plan is strategy would over-claim this CRA and Special-Purpose Programs extract. 3. A dual reading is still live in model-reason-code mapping that does not match notices for fair-lending officer in a bank with thin HMDA LAR quality. 4. Model-reason-code mapping that does not match notices is missing the fact fair-lending officer needs after a DOJ or CFPB monitor request for pricing files; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in model-reason-code mapping that does not match notices. 2. Check HMDA coding and underwriting policy against the CRA plan is. 3. Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files. 4. For this Fair Lending CRA and Special-Purpose Programs file, read model-reason-code mapping that does not match notices against a DOJ or CFPB monitor request for pricing files 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 / CRA and Special-Purpose Programs packet (model-reason-code mapping that does not match notices after a DOJ or CFPB monitor request for pricing files). Lead with the Fair Lending option model-reason-code mapping that does not match notices can support after a DOJ or CFPB monitor request for pricing files, then the two facts that force it, then the Monday action for fair-lending officer in a bank with thin HMDA LAR quality.