Assess whether the CRA plan is strategy or window dressing (7b491f)

SITUATION The working file is HMDA LAR validity and quality edits after a CRA PE that called the assessment area too narrow. Fair-lending officer in a bank with thin HMDA LAR quality has to name The CRA plan is strategy or Window dressing for this Fair Lending CRA and Special-Purpose Programs file.

DECISION Fair-lending officer in a bank with thin HMDA LAR quality must choose The CRA plan is strategy / Window dressing using HMDA LAR validity and quality edits after a CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. HMDA LAR validity and quality edits reads as The CRA plan is strategy once a CRA PE that called the assessment area too narrow is lined up to the same Fair Lending population. 2. HMDA LAR validity and quality edits is closer to Window dressing after a CRA PE that called the assessment area too narrow; The CRA plan is strategy would over-claim this CRA and Special-Purpose Programs extract. 3. A dual reading is still live in HMDA LAR validity and quality edits for fair-lending officer in a bank with thin HMDA LAR quality. 4. HMDA LAR validity and quality edits is missing the fact fair-lending officer needs after a CRA PE that called the assessment area too narrow; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Compare HMDA LAR validity and quality edits to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow. 2. Flag any disparate-impact table fair-lending officer cannot explain from HMDA LAR validity and quality edits. 3. Test a documented exception versus a pattern a bank with thin HMDA LAR quality must defend. 4. For this Fair Lending CRA and Special-Purpose Programs file, read HMDA LAR validity and quality edits against a CRA PE that called the assessment area too narrow and write the one fact that would move the CRA plan is for fair-lending officer.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / CRA and Special-Purpose Programs packet (HMDA LAR validity and quality edits after a CRA PE that called the assessment area too narrow). Lead with the Fair Lending option HMDA LAR validity and quality edits can support after a CRA PE that called the assessment area too narrow, then the two facts that force it, then the Monday action for fair-lending officer in a bank with thin HMDA LAR quality.

COMMAND RETURNS - Bottom-line Fair Lending option on the CRA plan is, then the evidence in HMDA LAR validity and quality edits, then the action for fair-lending officer - Hypothesis scorecard against HMDA LAR validity and quality edits: supported / rejected / untestable - Owner and next date for fair-lending officer in a bank with thin HMDA LAR quality - What changes the CRA plan is if a CRA PE that called the assessment area too narrow is later withdrawn