Whether the CRA plan is strategy or window dressing from HMDA LAR validity

Situation

Pricing and Credit Limits work in an institution preparing for a redlining exam now turns on the CRA plan is because a notice that cites 'other' as the principal reason 40% of the time put HMDA LAR validity and quality edits in play. Exam-response coordinator should say what HMDA LAR validity and quality edits proves.

Decision

Exam-response coordinator in an institution preparing for a redlining exam must choose The CRA plan is strategy / Window dressing using HMDA LAR validity and quality edits after a notice that cites 'other' as the principal reason 40% of the time.

Hypotheses to test

• The population in HMDA LAR validity and quality edits is the one a notice that cites 'other' as the principal reason 40% of the time named, so The CRA plan is strategy follows for this Pricing and Credit Limits file.
• The population in HMDA LAR validity and quality edits is adjacent only to a notice that cites 'other' as the principal reason 40% of the time; Window dressing is the honest Fair Lending call.
• An institution preparing for a redlining exam already contained a notice that cites 'other' as the principal reason 40% of the time before HMDA LAR validity and quality edits arrived; no new Pricing and Credit Limits path.
• Provenance on HMDA LAR validity and quality edits after a notice that cites 'other' as the principal reason 40% of the time is broken; do not pick The CRA plan is strategy or Window dressing yet.

Analysis required

• Flag any disparate-impact table exam-response coordinator cannot explain from HMDA LAR validity and quality edits.
• Test a documented exception versus a pattern an institution preparing for a redlining exam must defend.
• Match the adverse-action language to the facts in HMDA LAR validity and quality edits.
• For this Fair Lending Pricing and Credit Limits file, read HMDA LAR validity and quality edits against a notice that cites 'other' as the principal reason 40% of the time 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 / Pricing and Credit Limits packet (HMDA LAR validity and quality edits after a notice that cites 'other' as the principal reason 40% of the time). Lead with the Fair Lending option HMDA LAR validity and quality edits can support after a notice that cites 'other' as the principal reason 40% of the time, then the two facts that force it, then the Monday action for exam-response coordinator in an institution preparing for a redlining exam.