Assess whether the CRA plan is strategy or window dressing after a SPCP that

SITUATION A SPCP that originated almost no loans to the intended class put credit-card limit assignment disparity table in front of community-development lender in a mortgage company after a pricing-regression spike. This Fair Lending / Redlining and HMDA Data decision is the CRA plan is from credit-card limit assignment disparity table, and the live options are The CRA plan is strategy, Window dressing.

DECISION Community-development lender in a mortgage company after a pricing-regression spike must choose The CRA plan is strategy / Window dressing using credit-card limit assignment disparity table after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. Community-development lender can defend The CRA plan is strategy from credit-card limit assignment disparity table after a SPCP that originated almost no loans to the intended class in a Fair Lending challenge. 2. Community-development lender cannot defend The CRA plan is strategy from credit-card limit assignment disparity table; Window dressing is what the extract actually supports after a SPCP that originated almost no loans to the intended class. 3. A SPCP that originated almost no loans to the intended class never reached the population in credit-card limit assignment disparity table — reopen intake, do not close the CRA plan is. 4. Two facts in credit-card limit assignment disparity table after a SPCP that originated almost no loans to the intended class conflict for community-development lender; hold this Redlining and HMDA Data file.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the CRA plan is. 2. Compare credit-card limit assignment disparity table to similarly situated files, second-review notes, and reason codes after a SPCP that originated almost no loans to the intended class. 3. Flag any disparate-impact table community-development lender cannot explain from credit-card limit assignment disparity table. 4. For this Fair Lending Redlining and HMDA Data file, read credit-card limit assignment disparity table against a SPCP that originated almost no loans to the intended class 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 / Redlining and HMDA Data packet (credit-card limit assignment disparity table after a SPCP that originated almost no loans to the intended class). Lead with the Fair Lending option credit-card limit assignment disparity table can support after a SPCP that originated almost no loans to the intended class, then the two facts that force it, then the Monday action for community-development lender in a mortgage company after a pricing-regression spike.