CRA Plan: Strategy or Window Dressing — Mortgage Company

Situation

The CRA plan is sits with fair-lending officer because a HMDA resubmission that still fails quality edits hit a mortgage company after a pricing-regression spike. Evidence is manufactured-housing dealer overlay notes; write the Fair Lending Pricing and Credit Limits option that extract can carry.

Decision

Fair-lending officer in a mortgage company after a pricing-regression spike must choose The CRA plan is strategy / Window dressing using manufactured-housing dealer overlay notes after a HMDA resubmission that still fails quality edits.

Hypotheses to test

• The population in manufactured-housing dealer overlay notes is the one a HMDA resubmission that still fails quality edits named, so The CRA plan is strategy follows for this Pricing and Credit Limits file.
• The population in manufactured-housing dealer overlay notes is adjacent only to a HMDA resubmission that still fails quality edits; Window dressing is the honest Fair Lending call.
• A mortgage company after a pricing-regression spike already contained a HMDA resubmission that still fails quality edits before manufactured-housing dealer overlay notes arrived; no new Pricing and Credit Limits path.
• Provenance on manufactured-housing dealer overlay notes after a HMDA resubmission that still fails quality edits is broken; do not pick The CRA plan is strategy or Window dressing yet.

Analysis required

• Match the adverse-action language to the facts in manufactured-housing dealer overlay notes.
• Check HMDA coding and underwriting policy against the CRA plan is.
• Compare manufactured-housing dealer overlay notes to similarly situated files, second-review notes, and reason codes after a HMDA resubmission that still fails quality edits.
• For this Fair Lending Pricing and Credit Limits file, read manufactured-housing dealer overlay notes against a HMDA resubmission that still fails quality edits 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 / Pricing and Credit Limits packet (manufactured-housing dealer overlay notes after a HMDA resubmission that still fails quality edits). If manufactured-housing dealer overlay notes cannot force a Fair Lending label under Pricing and Credit Limits, stop. Do not invent pages a mortgage company after a pricing-regression spike does not have.