Assess whether the CRA plan is strategy or window dressing after a DOJ

SITUATION Adverse-action notice operations lead in a lender expanding into majority-minority census tracts has one working extract — underwriting exception log by branch — after a DOJ or CFPB monitor request for pricing files. If underwriting exception log by branch cannot support the CRA plan is, the only defensible Fair Lending output is hold.

DECISION Adverse-action notice operations lead in a lender expanding into majority-minority census tracts must choose The CRA plan is strategy / Window dressing using underwriting exception log by branch after a DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. Authorize The CRA plan is strategy now; underwriting exception log by branch already has the discriminator after a DOJ or CFPB monitor request for pricing files. 2. Keep Window dressing in force until underwriting exception log by branch is completed after a DOJ or CFPB monitor request for pricing files for adverse-action notice operations lead. 3. Treat underwriting exception log by branch as The CRA plan is strategy because both readings appear after a DOJ or CFPB monitor request for pricing files. 4. Refuse a Fair Lending close: adverse-action notice operations lead does not have the decision the CRA plan is turns on in underwriting exception log by branch.

ANALYSIS REQUIRED 1. Flag any disparate-impact table adverse-action notice operations lead cannot explain from underwriting exception log by branch. 2. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 3. Match the adverse-action language to the facts in underwriting exception log by branch. 4. For this Fair Lending Redlining and HMDA Data file, read underwriting exception log by branch against a DOJ or CFPB monitor request for pricing files and write the one fact that would move the CRA plan is for adverse-action notice operations lead.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / Redlining and HMDA Data packet (underwriting exception log by branch after a DOJ or CFPB monitor request for pricing files). The follow-on Redlining and HMDA Data action is what adverse-action notice operations lead 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 adverse-action notice operations lead - Hypothesis scorecard against underwriting exception log by branch: supported / rejected / untestable - What changes the CRA plan is if a DOJ or CFPB monitor request for pricing files is later withdrawn - Named option among The CRA plan is strategy, Window dressing and the fact that kills the others