Assess whether the CRA plan is strategy or window dressing (029bc9)

SITUATION A bank with thin HMDA LAR quality cannot treat a branch that stopped taking applications in one ZIP as incidental context on geographic application and origination heat map. Exam-response coordinator must close the CRA plan is from that extract under Fair Lending / Redlining and HMDA Data.

DECISION Exam-response coordinator in a bank with thin HMDA LAR quality must choose The CRA plan is strategy / Window dressing using geographic application and origination heat map after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. Authorize The CRA plan is strategy now; geographic application and origination heat map already has the discriminator after a branch that stopped taking applications in one ZIP. 2. Keep Window dressing in force until geographic application and origination heat map is completed after a branch that stopped taking applications in one ZIP for exam-response coordinator. 3. Treat geographic application and origination heat map as The CRA plan is strategy because both readings appear after a branch that stopped taking applications in one ZIP. 4. Refuse a Fair Lending close: exam-response coordinator does not have the decision the CRA plan is turns on in geographic application and origination heat map.

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 branch that stopped taking applications in one ZIP. 4. For this Fair Lending Redlining and HMDA Data file, read geographic application and origination heat map against a branch that stopped taking applications in one ZIP and write the one fact that would move the CRA plan is for exam-response coordinator.

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 branch that stopped taking applications in one ZIP). Lead with the Fair Lending option geographic application and origination heat map can support after a branch that stopped taking applications in one ZIP, then the two facts that force it, then the Monday action for exam-response coordinator in a bank with thin HMDA LAR quality.

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 exam-response coordinator - Hypothesis scorecard against geographic application and origination heat map: supported / rejected / untestable - Owner and next date for exam-response coordinator in a bank with thin HMDA LAR quality - What changes the CRA plan is if a branch that stopped taking applications in one ZIP is later withdrawn