Assess whether the CRA plan is strategy or window dressing (7b2503)

SITUATION CRA and Special-Purpose Programs work in an institution preparing for a redlining exam now turns on the CRA plan is because a branch that stopped taking applications in one ZIP put adverse-action notice principal-reason sample in play. CRA and Special-Purpose Programs work in an institution preparing for a redlining exam now turns on the CRA plan is because a branch that stopped taking applications in one ZIP put adverse-action notice principal-reason sample in play; community-development lender should say what adverse-action notice principal-reason sample proves for Fair Lending.

DECISION Community-development lender in an institution preparing for a redlining exam must choose The CRA plan is strategy / Window dressing using adverse-action notice principal-reason sample after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. Community-development lender can defend The CRA plan is strategy from adverse-action notice principal-reason sample after a branch that stopped taking applications in one ZIP in a Fair Lending challenge. 2. Community-development lender cannot defend The CRA plan is strategy from adverse-action notice principal-reason sample; Window dressing is what the extract actually supports after a branch that stopped taking applications in one ZIP. 3. A branch that stopped taking applications in one ZIP never reached the population in adverse-action notice principal-reason sample — reopen intake, do not close the CRA plan is. 4. Two facts in adverse-action notice principal-reason sample after a branch that stopped taking applications in one ZIP conflict for community-development lender; hold this CRA and Special-Purpose Programs file.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in adverse-action notice principal-reason sample. 2. Check HMDA coding and underwriting policy against the CRA plan is. 3. Compare adverse-action notice principal-reason sample to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP. 4. For this Fair Lending CRA and Special-Purpose Programs file, read adverse-action notice principal-reason sample against a branch that stopped taking applications in one ZIP 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 / CRA and Special-Purpose Programs packet (adverse-action notice principal-reason sample after a branch that stopped taking applications in one ZIP). If adverse-action notice principal-reason sample cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If adverse-action notice principal-reason sample after a branch that stopped taking applications in one ZIP cannot support The CRA plan is strategy versus Window dressing on this Fair Lending CRA and Special-Purpose Programs close, community-development lender must do not infer a control or scheme beyond the transaction and entitlement evidence.