Assess whether the CRA plan is strategy or window dressing (db1c30)

SITUATION A bank with thin HMDA LAR quality cannot treat a community complaint about appraisal gaps as incidental context on mortgage pricing residual by prohibited-basis group. CRA strategist must close the CRA plan is from that extract under Fair Lending / Examination and Notices.

DECISION CRA strategist in a bank with thin HMDA LAR quality must choose The CRA plan is strategy / Window dressing using mortgage pricing residual by prohibited-basis group after a community complaint about appraisal gaps.

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

ANALYSIS REQUIRED 1. Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps. 2. Flag any disparate-impact table CRA strategist cannot explain from mortgage pricing residual by prohibited-basis group. 3. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 4. For this Fair Lending Examination and Notices file, read mortgage pricing residual by prohibited-basis group against a community complaint about appraisal gaps and write the one fact that would move the CRA plan is for CRA strategist.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / Examination and Notices packet (mortgage pricing residual by prohibited-basis group after a community complaint about appraisal gaps). The follow-on Examination and Notices action is what CRA strategist 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 CRA strategist - Hypothesis scorecard against mortgage pricing residual by prohibited-basis group: supported / rejected / untestable - Examination and Notices 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 community complaint about appraisal gaps, if any