Assess whether the CRA plan is strategy or window dressing (170951)

SITUATION Examination and Notices work in a manufactured-housing lender with dealer-originated files now turns on the CRA plan is because a branch that stopped taking applications in one ZIP put underwriting exception log by branch in play. Examination and Notices work in a manufactured-housing lender with dealer-originated files now turns on the CRA plan is because a branch that stopped taking applications in one ZIP put underwriting exception log by branch in play; community-development lender should say what underwriting exception log by branch proves for Fair Lending.

DECISION Community-development lender in a manufactured-housing lender with dealer-originated files must choose The CRA plan is strategy / Window dressing using underwriting exception log by branch after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. Community-development lender can defend The CRA plan is strategy from underwriting exception log by branch after a branch that stopped taking applications in one ZIP in a Fair Lending challenge. 2. Community-development lender cannot defend The CRA plan is strategy from underwriting exception log by branch; Window dressing is what the extract actually supports after a branch that stopped taking applications in one ZIP. 3. A branch that stopped taking applications in one ZIP never reached the population in underwriting exception log by branch — reopen intake, do not close the CRA plan is. 4. Two facts in underwriting exception log by branch after a branch that stopped taking applications in one ZIP conflict for community-development lender; hold this Examination and Notices file.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the CRA plan is. 2. Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP. 3. Flag any disparate-impact table community-development lender cannot explain from underwriting exception log by branch. 4. For this Fair Lending Examination and Notices file, read underwriting exception log by branch against a branch that stopped taking applications in one ZIP 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 / Examination and Notices packet (underwriting exception log by branch after a branch that stopped taking applications in one ZIP). The follow-on Examination and Notices action is what community-development lender 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 underwriting exception log by branch, then the action for community-development lender - Hypothesis scorecard against underwriting exception log by branch: supported / rejected / untestable - Owner and next date for community-development lender in a manufactured-housing lender with dealer-originated files - What changes the CRA plan is if a branch that stopped taking applications in one ZIP is later withdrawn