Assess whether the CRA plan is strategy or window dressing (06f862)

SITUATION A HMDA resubmission that still fails quality edits put SPCP written plan versus actual originations in front of exam-response coordinator in a bank with thin HMDA LAR quality. This Fair Lending / Redlining and HMDA Data decision is the CRA plan is from SPCP written plan versus actual originations, and the live options are The CRA plan is strategy, Window dressing.

DECISION Exam-response coordinator in a bank with thin HMDA LAR quality must choose The CRA plan is strategy / Window dressing using SPCP written plan versus actual originations after a HMDA resubmission that still fails quality edits.

HYPOTHESES TO TEST 1. Authorize The CRA plan is strategy now; SPCP written plan versus actual originations already has the discriminator after a HMDA resubmission that still fails quality edits. 2. Keep Window dressing in force until SPCP written plan versus actual originations is completed after a HMDA resubmission that still fails quality edits for exam-response coordinator. 3. Treat SPCP written plan versus actual originations as The CRA plan is strategy because both readings appear after a HMDA resubmission that still fails quality edits. 4. Refuse a Fair Lending close: exam-response coordinator does not have the decision the CRA plan is turns on in SPCP written plan versus actual originations.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in SPCP written plan versus actual originations. 2. Check HMDA coding and underwriting policy against the CRA plan is. 3. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits. 4. For this Fair Lending Redlining and HMDA Data file, read SPCP written plan versus actual originations against a HMDA resubmission that still fails quality edits and write the one fact that would move the CRA plan is for exam-response coordinator.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / Redlining and HMDA Data packet (SPCP written plan versus actual originations after a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a HMDA resubmission that still fails quality edits, then the two facts that force it, then the Monday action for exam-response coordinator in a bank with thin HMDA LAR quality.

COMMAND RETURNS - Bottom-line Fair Lending option on the CRA plan is, then the evidence in SPCP written plan versus actual originations, then the action for exam-response coordinator - Hypothesis scorecard against SPCP written plan versus actual originations: supported / rejected / untestable - Regulatory or exam hook Redlining and HMDA Data would cite - Redlining and HMDA Data finding in SPCP written plan versus actual originations that a second reviewer can re-perform