Assess whether the CRA plan is strategy or window dressing (31e110)

SITUATION Community-development lender is responsible for the CRA plan is in a manufactured-housing lender, using dealer-originated files with mortgage pricing residual by prohibited-basis group as the only working extract. A marketing mailer that skipped majority-minority tracts is what reset the timeline for this Fair Lending Examination and Notices file.

DECISION Community-development lender in a manufactured-housing lender with dealer-originated files must choose The CRA plan is strategy / Window dressing using mortgage pricing residual by prohibited-basis group after a marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. Authorize The CRA plan is strategy now; mortgage pricing residual by prohibited-basis group already has the discriminator after a marketing mailer that skipped majority-minority tracts. 2. Keep Window dressing in force until mortgage pricing residual by prohibited-basis group is completed after a marketing mailer that skipped majority-minority tracts 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 marketing mailer that skipped majority-minority tracts. 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. Check HMDA coding and underwriting policy against the CRA plan is. 2. Compare mortgage pricing residual by prohibited-basis group to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts. 3. Flag any disparate-impact table community-development lender cannot explain from 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 marketing mailer that skipped majority-minority tracts 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 / Examination and Notices packet (mortgage pricing residual by prohibited-basis group after a marketing mailer that skipped majority-minority tracts). Lead with the Fair Lending option mortgage pricing residual by prohibited-basis group can support after a marketing mailer that skipped majority-minority tracts, then the two facts that force it, then the Monday action for community-development lender in a manufactured-housing lender with dealer-originated files.

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 - Owner and next date for community-development lender in a manufactured-housing lender with dealer-originated files - What changes the CRA plan is if a marketing mailer that skipped majority-minority tracts is later withdrawn