Assess whether the CRA plan is strategy or window dressing (8601a9)

SITUATION After a branch that stopped taking applications in one ZIP, mortgage pricing residual by prohibited-basis group is what community-development lender can touch in a mortgage company after a pricing-regression spike. Fair Lending will live with The CRA plan is strategy versus Window dressing on this Redlining and HMDA Data file.

DECISION Community-development lender in a mortgage company after a pricing-regression spike must choose The CRA plan is strategy / Window dressing using mortgage pricing residual by prohibited-basis group after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. Authorize The CRA plan is strategy now; mortgage pricing residual by prohibited-basis group already has the discriminator after a branch that stopped taking applications in one ZIP. 2. Keep Window dressing in force until mortgage pricing residual by prohibited-basis group is completed after a branch that stopped taking applications in one ZIP for community-development lender. 3. Treat mortgage pricing residual by prohibited-basis group as The CRA plan is strategy because both readings appear after a branch that stopped taking applications in one ZIP. 4. Refuse a Fair Lending close: community-development lender does not have the decision the CRA plan is turns on in mortgage pricing residual by prohibited-basis group.

ANALYSIS REQUIRED 1. Flag any disparate-impact table community-development lender cannot explain from mortgage pricing residual by prohibited-basis group. 2. Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend. 3. Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group. 4. For this Fair Lending Redlining and HMDA Data file, read mortgage pricing residual by prohibited-basis group 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 / Redlining and HMDA Data packet (mortgage pricing residual by prohibited-basis group after a branch that stopped taking applications in one ZIP). The follow-on Redlining and HMDA Data 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 mortgage pricing residual by prohibited-basis group, then the action for community-development lender - Hypothesis scorecard against mortgage pricing residual by prohibited-basis group: supported / rejected / untestable - Redlining and HMDA Data finding in mortgage pricing residual by prohibited-basis group that a second reviewer can re-perform - Missing page in mortgage pricing residual by prohibited-basis group after a branch that stopped taking applications in one ZIP, if any