Whether the CRA plan is strategy or window dressing from small-business

Situation

The CRA plan is sits with fair-lending officer because a SPCP that originated almost no loans to the intended class hit a manufactured-housing lender with dealer-originated files. Evidence is small-business decline comparative file set; write the Fair Lending Redlining and HMDA Data option that extract can carry.

Decision

Fair-lending officer in a manufactured-housing lender with dealer-originated files must choose The CRA plan is strategy / Window dressing using small-business decline comparative file set after a SPCP that originated almost no loans to the intended class.

Hypotheses to test

• Fair-lending officer can defend The CRA plan is strategy from small-business decline comparative file set after a SPCP that originated almost no loans to the intended class in a Fair Lending challenge.
• Fair-lending officer cannot defend The CRA plan is strategy from small-business decline comparative file set; Window dressing is what the extract actually supports after a SPCP that originated almost no loans to the intended class.
• A SPCP that originated almost no loans to the intended class never reached the population in small-business decline comparative file set — reopen intake, do not close the CRA plan is.
• Two facts in small-business decline comparative file set after a SPCP that originated almost no loans to the intended class conflict for fair-lending officer; hold this Redlining and HMDA Data file.

Analysis required

• Match the adverse-action language to the facts in small-business decline comparative file set.
• Check HMDA coding and underwriting policy against the CRA plan is.
• Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class.
• For this Fair Lending Redlining and HMDA Data file, read small-business decline comparative file set against a SPCP that originated almost no loans to the intended class 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 / Redlining and HMDA Data packet (small-business decline comparative file set after a SPCP that originated almost no loans to the intended class). Lead with the Fair Lending option small-business decline comparative file set can support after a SPCP that originated almost no loans to the intended class, then the two facts that force it, then the Monday action for fair-lending officer in a manufactured-housing lender with dealer-originated files.