Assess whether the CRA plan is strategy or window dressing from geographic

SITUATION An institution preparing for a redlining exam cannot treat a community complaint about appraisal gaps as incidental context on geographic application and origination heat map. CRA strategist must close the CRA plan is from that extract under Fair Lending / Redlining and HMDA Data.

DECISION CRA strategist in an institution preparing for a redlining exam must choose The CRA plan is strategy / Window dressing using geographic application and origination heat map after a community complaint about appraisal gaps.

HYPOTHESES TO TEST 1. Geographic application and origination heat map reads as The CRA plan is strategy once a community complaint about appraisal gaps is lined up to the same Fair Lending population. 2. Geographic application and origination heat map is closer to Window dressing after a community complaint about appraisal gaps; The CRA plan is strategy would over-claim this Redlining and HMDA Data extract. 3. A dual reading is still live in geographic application and origination heat map for CRA strategist in an institution preparing for a redlining exam. 4. Geographic application and origination heat map is missing the fact CRA strategist needs after a community complaint about appraisal gaps; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in geographic application and origination heat map. 2. Check HMDA coding and underwriting policy against the CRA plan is. 3. Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps. 4. For this Fair Lending Redlining and HMDA Data file, read geographic application and origination heat map against a community complaint about appraisal gaps 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 / Redlining and HMDA Data packet (geographic application and origination heat map after a community complaint about appraisal gaps). If geographic application and origination heat map cannot force a Fair Lending label under Redlining and HMDA Data, stop. If geographic application and origination heat map after a community complaint about appraisal gaps cannot support The CRA plan is strategy versus Window dressing on this Fair Lending Redlining and HMDA Data close, CRA strategist must do not infer a control or scheme beyond the transaction and entitlement evidence.

COMMAND RETURNS - Bottom-line Fair Lending option on the CRA plan is, then the evidence in geographic application and origination heat map, then the action for CRA strategist - Hypothesis scorecard against geographic application and origination heat map: supported / rejected / untestable - Owner and next date for CRA strategist in an institution preparing for a redlining exam - What changes the CRA plan is if a community complaint about appraisal gaps is later withdrawn