Assess whether the CRA plan is strategy or window dressing (f337c0)

SITUATION CRA and Special-Purpose Programs work in a manufactured-housing lender with dealer-originated files now turns on the CRA plan is because a community complaint about appraisal gaps put appraisal-gap outcomes in majority-minority tracts in play. CRA and Special-Purpose Programs work in a manufactured-housing lender with dealer-originated files now turns on the CRA plan is because a community complaint about appraisal gaps put appraisal-gap outcomes in majority-minority tracts in play; exam-response coordinator should say what appraisal-gap outcomes in majority-minority tracts proves for Fair Lending.

DECISION Exam-response coordinator in a manufactured-housing lender with dealer-originated files must choose The CRA plan is strategy / Window dressing using appraisal-gap outcomes in majority-minority tracts after a community complaint about appraisal gaps.

HYPOTHESES TO TEST 1. Authorize The CRA plan is strategy now; appraisal-gap outcomes in majority-minority tracts already has the discriminator after a community complaint about appraisal gaps. 2. Keep Window dressing in force until appraisal-gap outcomes in majority-minority tracts is completed after a community complaint about appraisal gaps for exam-response coordinator. 3. Treat appraisal-gap outcomes in majority-minority tracts as The CRA plan is strategy because both readings appear after a community complaint about appraisal gaps. 4. Refuse a Fair Lending close: exam-response coordinator does not have the decision the CRA plan is turns on in appraisal-gap outcomes in majority-minority tracts.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the CRA plan is. 2. Compare appraisal-gap outcomes in majority-minority tracts to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps. 3. Flag any disparate-impact table exam-response coordinator cannot explain from appraisal-gap outcomes in majority-minority tracts. 4. For this Fair Lending CRA and Special-Purpose Programs file, read appraisal-gap outcomes in majority-minority tracts against a community complaint about appraisal gaps 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 / CRA and Special-Purpose Programs packet (appraisal-gap outcomes in majority-minority tracts after a community complaint about appraisal gaps). Lead with the Fair Lending option appraisal-gap outcomes in majority-minority tracts can support after a community complaint about appraisal gaps, then the two facts that force it, then the Monday action for exam-response coordinator in a manufactured-housing lender with dealer-originated files.