Assess whether the CRA plan is strategy or window dressing (5acd45)

SITUATION The CRA plan is sits with model-risk partner for credit scoring because a CRA PE that called the assessment area too narrow hit a lender expanding into majority-minority census tracts. Evidence is mortgage pricing residual by prohibited-basis group; write the Fair Lending Examination and Notices option that extract can carry.

DECISION Model-risk partner for credit scoring in a lender expanding into majority-minority census tracts must choose The CRA plan is strategy / Window dressing using mortgage pricing residual by prohibited-basis group after a CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. Model-risk partner for credit scoring can defend The CRA plan is strategy from mortgage pricing residual by prohibited-basis group after a CRA PE that called the assessment area too narrow in a Fair Lending challenge. 2. Model-risk partner for credit scoring cannot defend The CRA plan is strategy from mortgage pricing residual by prohibited-basis group; Window dressing is what the extract actually supports after a CRA PE that called the assessment area too narrow. 3. A CRA PE that called the assessment area too narrow never reached the population in mortgage pricing residual by prohibited-basis group — reopen intake, do not close the CRA plan is. 4. Two facts in mortgage pricing residual by prohibited-basis group after a CRA PE that called the assessment area too narrow conflict for model-risk partner for credit scoring; hold this Examination and Notices file.

ANALYSIS REQUIRED 1. Flag any disparate-impact table model-risk partner for credit scoring cannot explain from mortgage pricing residual by prohibited-basis group. 2. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 3. Match the adverse-action language to the facts in mortgage pricing residual by prohibited-basis group. 4. For this Fair Lending Examination and Notices file, read mortgage pricing residual by prohibited-basis group against a CRA PE that called the assessment area too narrow and write the one fact that would move the CRA plan is for model-risk partner for credit scoring.

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 CRA PE that called the assessment area too narrow). Lead with the Fair Lending option mortgage pricing residual by prohibited-basis group can support after a CRA PE that called the assessment area too narrow, then the two facts that force it, then the Monday action for model-risk partner for credit scoring in a lender expanding into majority-minority census tracts.