Assess whether the CRA plan is strategy or window dressing (b06ff3)

SITUATION In an institution preparing for a redlining exam, small-business decline comparative file set is the evidence after a community complaint about appraisal gaps. Fair-lending officer has to pick The CRA plan is strategy or Window dressing for this Fair Lending Examination and Notices close using small-business decline comparative file set.

DECISION Fair-lending officer 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 community complaint about appraisal gaps.

HYPOTHESES TO TEST 1. A community complaint about appraisal gaps is noise around an already-controlled Examination and Notices process in an institution preparing for a redlining exam, given small-business decline comparative file set. 2. A community complaint about appraisal gaps is the event in small-business decline comparative file set that forces The CRA plan is strategy for fair-lending officer under Fair Lending. 3. Small-business decline comparative file set shows a one-file miss after a community complaint about appraisal gaps, not a Examination and Notices program failure. 4. Small-business decline comparative file set cannot decide the CRA plan is yet after a community complaint about appraisal gaps; hold is the only Fair Lending close an institution preparing for a redlining exam can defend.

ANALYSIS REQUIRED 1. Flag any disparate-impact table fair-lending officer cannot explain from small-business decline comparative file set. 2. Test a documented exception versus a pattern an institution preparing for a redlining exam must defend. 3. Match the adverse-action language to the facts in small-business decline comparative file set. 4. For this Fair Lending Examination and Notices file, read small-business decline comparative file set against a community complaint about appraisal gaps 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 / Examination and Notices packet (small-business decline comparative file set after a community complaint about appraisal gaps). The follow-on Examination and Notices action is what fair-lending officer 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 fair-lending officer - Hypothesis scorecard against small-business decline comparative file set: supported / rejected / untestable - What changes the CRA plan is if a community complaint about appraisal gaps is later withdrawn - Named option among The CRA plan is strategy, Window dressing and the fact that kills the others