CRA strategist must resolve whether the CRA plan is strategy or window

Situation

Pricing and Credit Limits work in a manufactured-housing lender with dealer-originated files now turns on the CRA plan is because a branch that stopped taking applications in one ZIP put CRA assessment-area versus lending footprint in play. CRA strategist should say what CRA assessment-area versus lending footprint proves.

Decision

CRA strategist in a manufactured-housing lender with dealer-originated files must choose The CRA plan is strategy / Window dressing using CRA assessment-area versus lending footprint after a branch that stopped taking applications in one ZIP.

Hypotheses to test

• The population in CRA assessment-area versus lending footprint is the one a branch that stopped taking applications in one ZIP named, so The CRA plan is strategy follows for this Pricing and Credit Limits file.
• The population in CRA assessment-area versus lending footprint is adjacent only to a branch that stopped taking applications in one ZIP; Window dressing is the honest Fair Lending call.
• A manufactured-housing lender with dealer-originated files already contained a branch that stopped taking applications in one ZIP before CRA assessment-area versus lending footprint arrived; no new Pricing and Credit Limits path.
• Provenance on CRA assessment-area versus lending footprint after a branch that stopped taking applications in one ZIP is broken; do not pick The CRA plan is strategy or Window dressing yet.

Analysis required

• Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP.
• Flag any disparate-impact table CRA strategist cannot explain from CRA assessment-area versus lending footprint.
• Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend.
• For this Fair Lending Pricing and Credit Limits file, read CRA assessment-area versus lending footprint against a branch that stopped taking applications in one ZIP and write the one fact that would move the CRA plan is for CRA strategist.

Recommendation

Choose The CRA plan is strategy / Window dressing on this Fair Lending / Pricing and Credit Limits packet (CRA assessment-area versus lending footprint after a branch that stopped taking applications in one ZIP). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after a branch that stopped taking applications in one ZIP, then the two facts that force it, then the Monday action for CRA strategist in a manufactured-housing lender with dealer-originated files.