Assess whether the CRA plan is strategy or window dressing after an exception

SITUATION Geographic application and origination heat map arrived with an exception rate twice as high for one group after credit controls for community-development lender. That is a Fair Lending Redlining and HMDA Data decision on the CRA plan is in a mortgage company after a pricing-regression spike.

DECISION Community-development lender in a mortgage company after a pricing-regression spike must choose The CRA plan is strategy / Window dressing using geographic application and origination heat map after an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. Geographic application and origination heat map reads as The CRA plan is strategy once an exception rate twice as high for one group after credit controls is lined up to the same Fair Lending population. 2. Geographic application and origination heat map is closer to Window dressing after an exception rate twice as high for one group after credit controls; 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 community-development lender in a mortgage company after a pricing-regression spike. 4. Geographic application and origination heat map is missing the fact community-development lender needs after an exception rate twice as high for one group after credit controls; 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 an exception rate twice as high for one group after credit controls. 4. For this Fair Lending Redlining and HMDA Data file, read geographic application and origination heat map against an exception rate twice as high for one group after credit controls 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 (geographic application and origination heat map after an exception rate twice as high for one group after credit controls). 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 an exception rate twice as high for one group after credit controls cannot support The CRA plan is strategy versus Window dressing on this Fair Lending Redlining and HMDA Data close, community-development lender must do not infer a control or scheme beyond the transaction and entitlement evidence.