Assess whether the CRA plan is strategy or window dressing (f26d42)

SITUATION In an institution preparing for a redlining exam, small-business decline comparative file set is the evidence after a marketing mailer that skipped majority-minority tracts. Community-development lender has to pick The CRA plan is strategy or Window dressing for this Fair Lending CRA and Special-Purpose Programs close using small-business decline comparative file set.

DECISION Community-development lender in an institution preparing for a redlining exam must choose The CRA plan is strategy / Window dressing using small-business decline comparative file set after a marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. Authorize The CRA plan is strategy now; small-business decline comparative file set already has the discriminator after a marketing mailer that skipped majority-minority tracts. 2. Keep Window dressing in force until small-business decline comparative file set is completed after a marketing mailer that skipped majority-minority tracts for community-development lender. 3. Treat small-business decline comparative file set as The CRA plan is strategy because both readings appear after a marketing mailer that skipped majority-minority tracts. 4. Refuse a Fair Lending close: community-development lender does not have the decision the CRA plan is turns on in small-business decline comparative file set.

ANALYSIS REQUIRED 1. Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts. 2. Flag any disparate-impact table community-development lender cannot explain from small-business decline comparative file set. 3. Test a documented exception versus a pattern an institution preparing for a redlining exam must defend. 4. For this Fair Lending CRA and Special-Purpose Programs file, read small-business decline comparative file set against a marketing mailer that skipped majority-minority tracts 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 / CRA and Special-Purpose Programs packet (small-business decline comparative file set after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option small-business decline comparative file set can support after a marketing mailer that skipped majority-minority tracts, then the two facts that force it, then the Monday action for community-development lender in an institution preparing for a redlining exam.

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 community-development lender - Hypothesis scorecard against small-business decline comparative file set: supported / rejected / untestable - CRA and Special-Purpose Programs 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 marketing mailer that skipped majority-minority tracts, if any