Whether the CRA plan is strategy or window dressing from model-reason-code

SITUATION Pricing and Credit Limits work in a lender expanding into majority-minority census tracts now turns on the CRA plan is because a board asking if the bank should settle a matched-pair study put model-reason-code mapping that does not match notices in play. HMDA data-quality manager should say what model-reason-code mapping that does not match notices proves.

DECISION HMDA data-quality manager in a lender expanding into majority-minority census tracts must choose The CRA plan is strategy / Window dressing using model-reason-code mapping that does not match notices after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. Model-reason-code mapping that does not match notices reads as The CRA plan is strategy once a board asking if the bank should settle a matched-pair study is lined up to the same Fair Lending population. 2. Model-reason-code mapping that does not match notices is closer to Window dressing after a board asking if the bank should settle a matched-pair study; The CRA plan is strategy would over-claim this Pricing and Credit Limits extract. 3. A dual reading is still live in model-reason-code mapping that does not match notices for HMDA data-quality manager in a lender expanding into majority-minority census tracts. 4. Model-reason-code mapping that does not match notices is missing the fact HMDA data-quality manager needs after a board asking if the bank should settle a matched-pair study; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the CRA plan is. 2. Compare model-reason-code mapping that does not match notices to similarly situated files, second-review notes, and reason codes after a board asking if the bank should settle a matched-pair study. 3. Flag any disparate-impact table HMDA data-quality manager cannot explain from model-reason-code mapping that does not match notices. 4. For this Fair Lending Pricing and Credit Limits file, read model-reason-code mapping that does not match notices against a board asking if the bank should settle a matched-pair study and write the one fact that would move the CRA plan is for HMDA data-quality manager.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / Pricing and Credit Limits packet (model-reason-code mapping that does not match notices after a board asking if the bank should settle a matched-pair study). Lead with the Fair Lending option model-reason-code mapping that does not match notices can support after a board asking if the bank should settle a matched-pair study, then the two facts that force it, then the Monday action for HMDA data-quality manager in a lender expanding into majority-minority census tracts.