Whether the CRA plan is strategy or window dressing from appraisal-gap

SITUATION In a lender expanding into majority-minority census tracts, appraisal-gap outcomes in majority-minority tracts is the evidence after a SPCP that originated almost no loans to the intended class. HMDA data-quality manager has to pick The CRA plan is strategy or Window dressing for this Fair Lending Pricing and Credit Limits close using appraisal-gap outcomes in majority-minority tracts.

DECISION HMDA data-quality manager in a lender expanding into majority-minority census tracts must choose The CRA plan is strategy / Window dressing using appraisal-gap outcomes in majority-minority tracts after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. HMDA data-quality manager can defend The CRA plan is strategy from appraisal-gap outcomes in majority-minority tracts after a SPCP that originated almost no loans to the intended class in a Fair Lending challenge. 2. HMDA data-quality manager cannot defend The CRA plan is strategy from appraisal-gap outcomes in majority-minority tracts; Window dressing is what the extract actually supports after a SPCP that originated almost no loans to the intended class. 3. A SPCP that originated almost no loans to the intended class never reached the population in appraisal-gap outcomes in majority-minority tracts — reopen intake, do not close the CRA plan is. 4. Two facts in appraisal-gap outcomes in majority-minority tracts after a SPCP that originated almost no loans to the intended class conflict for HMDA data-quality manager; hold this Pricing and Credit Limits file.

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 SPCP that originated almost no loans to the intended class. 3. Flag any disparate-impact table HMDA data-quality manager cannot explain from appraisal-gap outcomes in majority-minority tracts. 4. For this Fair Lending Pricing and Credit Limits file, read appraisal-gap outcomes in majority-minority tracts against a SPCP that originated almost no loans to the intended class 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 / Pricing and Credit Limits packet (appraisal-gap outcomes in majority-minority tracts after a SPCP that originated almost no loans to the intended class). The follow-on Pricing and Credit Limits action is what HMDA data-quality manager 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 appraisal-gap outcomes in majority-minority tracts, then the action for HMDA data-quality manager - Hypothesis scorecard against appraisal-gap outcomes in majority-minority tracts: supported / rejected / untestable - Named option among The CRA plan is strategy, Window dressing and the fact that kills the others - Owner and next date for HMDA data-quality manager in a lender expanding into majority-minority census tracts