Assess whether the CRA plan is strategy or window dressing (8d718f)

SITUATION A DOJ or CFPB monitor request for pricing files put CRA assessment-area versus lending footprint in front of community-development lender in a manufactured-housing lender with dealer-originated files. This Fair Lending / Examination and Notices decision is the CRA plan is from CRA assessment-area versus lending footprint, and the live options are The CRA plan is strategy, Window dressing.

DECISION Community-development lender 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 DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. Community-development lender can defend The CRA plan is strategy from CRA assessment-area versus lending footprint after a DOJ or CFPB monitor request for pricing files in a Fair Lending challenge. 2. Community-development lender cannot defend The CRA plan is strategy from CRA assessment-area versus lending footprint; Window dressing is what the extract actually supports after a DOJ or CFPB monitor request for pricing files. 3. A DOJ or CFPB monitor request for pricing files never reached the population in CRA assessment-area versus lending footprint — reopen intake, do not close the CRA plan is. 4. Two facts in CRA assessment-area versus lending footprint after a DOJ or CFPB monitor request for pricing files conflict for community-development lender; hold this Examination and Notices file.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the CRA plan is. 2. Compare CRA assessment-area versus lending footprint to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files. 3. Flag any disparate-impact table community-development lender cannot explain from CRA assessment-area versus lending footprint. 4. For this Fair Lending Examination and Notices file, read CRA assessment-area versus lending footprint against a DOJ or CFPB monitor request for pricing files 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 (CRA assessment-area versus lending footprint after a DOJ or CFPB monitor request for pricing files). Lead with the Fair Lending option CRA assessment-area versus lending footprint can support after a DOJ or CFPB monitor request for pricing files, 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 CRA assessment-area versus lending footprint, then the action for community-development lender - Hypothesis scorecard against CRA assessment-area versus lending footprint: supported / rejected / untestable - Named option among The CRA plan is strategy, Window dressing and the fact that kills the others - Owner and next date for community-development lender in a manufactured-housing lender with dealer-originated files