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

SITUATION In a mortgage company after a pricing-regression spike, a branch that stopped taking applications in one ZIP put appraisal-gap outcomes in majority-minority tracts in play. Fair-lending officer should decide whether the CRA plan is strategy or window dressing without filling gaps appraisal-gap outcomes in majority-minority tracts does not contain.

DECISION Fair-lending officer in a mortgage company after a pricing-regression spike must choose The CRA plan is strategy / Window dressing using appraisal-gap outcomes in majority-minority tracts after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. Fair-lending officer can defend The CRA plan is strategy from appraisal-gap outcomes in majority-minority tracts after a branch that stopped taking applications in one ZIP in a Fair Lending challenge. 2. Fair-lending officer 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 branch that stopped taking applications in one ZIP. 3. A branch that stopped taking applications in one ZIP 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 branch that stopped taking applications in one ZIP conflict for fair-lending officer; 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 branch that stopped taking applications in one ZIP. 3. Flag any disparate-impact table fair-lending officer 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 branch that stopped taking applications in one ZIP and write the one fact that would move the CRA plan is for fair-lending officer.

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 branch that stopped taking applications in one ZIP). Lead with the Fair Lending option appraisal-gap outcomes in majority-minority tracts can support after a branch that stopped taking applications in one ZIP, then the two facts that force it, then the Monday action for fair-lending officer in a mortgage company after a pricing-regression spike.

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 fair-lending officer - Hypothesis scorecard against appraisal-gap outcomes in majority-minority tracts: supported / rejected / untestable - Owner and next date for fair-lending officer in a mortgage company after a pricing-regression spike - What changes the CRA plan is if a branch that stopped taking applications in one ZIP is later withdrawn