Assess whether the CRA plan is strategy or window dressing (b86da1)

SITUATION In a lender expanding into majority-minority census tracts, small-business decline comparative file set is the evidence after a DOJ or CFPB monitor request for pricing files. Adverse-action notice operations lead has to pick The CRA plan is strategy or Window dressing for this Fair Lending Redlining and HMDA Data close using small-business decline comparative file set.

DECISION Adverse-action notice operations lead in a lender expanding into majority-minority census tracts must choose The CRA plan is strategy / Window dressing using small-business decline comparative file set after a DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. A DOJ or CFPB monitor request for pricing files is noise around an already-controlled Redlining and HMDA Data process in a lender expanding into majority-minority census tracts, given small-business decline comparative file set. 2. A DOJ or CFPB monitor request for pricing files is the event in small-business decline comparative file set that forces The CRA plan is strategy for adverse-action notice operations lead under Fair Lending. 3. Small-business decline comparative file set shows a one-file miss after a DOJ or CFPB monitor request for pricing files, not a Redlining and HMDA Data program failure. 4. Small-business decline comparative file set cannot decide the CRA plan is yet after a DOJ or CFPB monitor request for pricing files; hold is the only Fair Lending close a lender expanding into majority-minority census tracts can defend.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 2. Match the adverse-action language to the facts in small-business decline comparative file set. 3. Check HMDA coding and underwriting policy against the CRA plan is. 4. For this Fair Lending Redlining and HMDA Data file, read small-business decline comparative file set against a DOJ or CFPB monitor request for pricing files and write the one fact that would move the CRA plan is for adverse-action notice operations lead.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / Redlining and HMDA Data packet (small-business decline comparative file set after a DOJ or CFPB monitor request for pricing files). The follow-on Redlining and HMDA Data action is what adverse-action notice operations lead 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 small-business decline comparative file set, then the action for adverse-action notice operations lead - Hypothesis scorecard against small-business decline comparative file set: supported / rejected / untestable - Redlining and HMDA Data finding in small-business decline comparative file set that a second reviewer can re-perform - Missing page in small-business decline comparative file set after a DOJ or CFPB monitor request for pricing files, if any