Whether the CRA plan is strategy or window dressing from underwriting

Situation

A bank with thin HMDA LAR quality cannot treat a HMDA resubmission that still fails quality edits as color commentary on underwriting exception log by branch. Exam-response coordinator must close the CRA plan is from that extract under Fair Lending / Redlining and HMDA Data.

Decision

Exam-response coordinator in a bank with thin HMDA LAR quality must choose The CRA plan is strategy / Window dressing using underwriting exception log by branch after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• Underwriting exception log by branch reads as The CRA plan is strategy once a HMDA resubmission that still fails quality edits is lined up to the same Fair Lending population.
• Underwriting exception log by branch is closer to Window dressing after a HMDA resubmission that still fails quality edits; The CRA plan is strategy would over-claim this Redlining and HMDA Data extract.
• A dual reading is still live in underwriting exception log by branch for exam-response coordinator in a bank with thin HMDA LAR quality.
• Underwriting exception log by branch is missing the fact exam-response coordinator needs after a HMDA resubmission that still fails quality edits; stop this Fair Lending close.

Analysis required

• Check HMDA coding and underwriting policy against the CRA plan is.
• Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits.
• Flag any disparate-impact table exam-response coordinator cannot explain from underwriting exception log by branch.
• For this Fair Lending Redlining and HMDA Data file, read underwriting exception log by branch 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 (underwriting exception log by branch after a HMDA resubmission that still fails quality edits). Lead with the Fair Lending option underwriting exception log by branch 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.