Assess whether the CRA plan is strategy or window dressing (41d589)

SITUATION After a SPCP that originated almost no loans to the intended class, manufactured-housing dealer overlay notes is what second-review underwriter can touch in a lender expanding into majority-minority census tracts. Fair Lending will live with The CRA plan is strategy versus Window dressing on this CRA and Special-Purpose Programs file.

DECISION Second-review underwriter in a lender expanding into majority-minority census tracts must choose The CRA plan is strategy / Window dressing using manufactured-housing dealer overlay notes after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. A SPCP that originated almost no loans to the intended class is noise around an already-controlled CRA and Special-Purpose Programs process in a lender expanding into majority-minority census tracts, given manufactured-housing dealer overlay notes. 2. A SPCP that originated almost no loans to the intended class is the event in manufactured-housing dealer overlay notes that forces The CRA plan is strategy for second-review underwriter under Fair Lending. 3. Manufactured-housing dealer overlay notes shows a one-file miss after a SPCP that originated almost no loans to the intended class, not a CRA and Special-Purpose Programs program failure. 4. Manufactured-housing dealer overlay notes cannot decide the CRA plan is yet after a SPCP that originated almost no loans to the intended class; hold is the only Fair Lending close a lender expanding into majority-minority census tracts can defend.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a lender expanding into majority-minority census tracts must defend. 2. Match the adverse-action language to the facts in manufactured-housing dealer overlay notes. 3. Check HMDA coding and underwriting policy against the CRA plan is. 4. For this Fair Lending CRA and Special-Purpose Programs file, read manufactured-housing dealer overlay notes against a SPCP that originated almost no loans to the intended class and write the one fact that would move the CRA plan is for second-review underwriter.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / CRA and Special-Purpose Programs packet (manufactured-housing dealer overlay notes after a SPCP that originated almost no loans to the intended class). If manufactured-housing dealer overlay notes cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If manufactured-housing dealer overlay notes after a SPCP that originated almost no loans to the intended class cannot support The CRA plan is strategy versus Window dressing on this Fair Lending CRA and Special-Purpose Programs close, second-review underwriter must do not infer a control or scheme beyond the transaction and entitlement evidence.