Assess whether the CRA plan is strategy or window dressing (c260fe)

SITUATION The CRA plan is sits with community-development lender because an exception rate twice as high for one group after credit controls hit a manufactured-housing lender with dealer-originated files. Evidence is mortgage pricing residual by prohibited-basis group; write the Fair Lending Examination and Notices option that extract can carry.

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 an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. Authorize The CRA plan is strategy now; mortgage pricing residual by prohibited-basis group already has the discriminator after an exception rate twice as high for one group after credit controls. 2. Keep Window dressing in force until mortgage pricing residual by prohibited-basis group is completed after an exception rate twice as high for one group after credit controls for community-development lender. 3. Treat mortgage pricing residual by prohibited-basis group as The CRA plan is strategy because both readings appear after an exception rate twice as high for one group after credit controls. 4. Refuse a Fair Lending close: community-development lender does not have the page the CRA plan is turns on in mortgage pricing residual by prohibited-basis group.

ANALYSIS REQUIRED 1. Flag any disparate-impact table community-development lender cannot explain from mortgage pricing residual by prohibited-basis group. 2. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files 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 an exception rate twice as high for one group after credit controls 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 an exception rate twice as high for one group after credit controls). Lead with the Fair Lending option mortgage pricing residual by prohibited-basis group can support after an exception rate twice as high for one group after credit controls, 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 - Missing page in mortgage pricing residual by prohibited-basis group after an exception rate twice as high for one group after credit controls, if any - Regulatory or exam hook Examination and Notices would cite