Assess whether the CRA plan is strategy or window dressing (12b736)

SITUATION After a marketing mailer that skipped majority-minority tracts, underwriting exception log by branch is what HMDA data-quality manager can touch in a small-business desk using a new vendor score. Fair Lending will live with The CRA plan is strategy versus Window dressing on this Examination and Notices file.

DECISION HMDA data-quality manager in a small-business desk using a new vendor score must choose The CRA plan is strategy / Window dressing using underwriting exception log by branch after a marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. HMDA data-quality manager can defend The CRA plan is strategy from underwriting exception log by branch after a marketing mailer that skipped majority-minority tracts in a Fair Lending challenge. 2. HMDA data-quality manager cannot defend The CRA plan is strategy from underwriting exception log by branch; Window dressing is what the extract actually supports after a marketing mailer that skipped majority-minority tracts. 3. A marketing mailer that skipped majority-minority tracts 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 marketing mailer that skipped majority-minority tracts conflict for HMDA data-quality manager; hold this Examination and Notices file.

ANALYSIS REQUIRED 1. Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts. 2. Flag any disparate-impact table HMDA data-quality manager cannot explain from underwriting exception log by branch. 3. Test a documented exception versus a pattern a small-business desk using a new vendor score must defend. 4. For this Fair Lending Examination and Notices file, read underwriting exception log by branch against a marketing mailer that skipped majority-minority tracts and write the one fact that would move the CRA plan is for HMDA data-quality manager.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / Examination and Notices packet (underwriting exception log by branch after a marketing mailer that skipped majority-minority tracts). If underwriting exception log by branch cannot force a Fair Lending label under Examination and Notices, stop. If underwriting exception log by branch after a marketing mailer that skipped majority-minority tracts cannot support The CRA plan is strategy versus Window dressing on this Fair Lending Examination and Notices close, HMDA data-quality manager must do not infer a control or scheme beyond the transaction and entitlement evidence.