Assess whether the CRA plan is strategy or window dressing (36756e)

SITUATION Exam-response coordinator in a mortgage company after a pricing-regression spike has one working extract — model-reason-code mapping that does not match notices — after a marketing mailer that skipped majority-minority tracts. If model-reason-code mapping that does not match notices cannot support the CRA plan is, the only defensible Fair Lending output is hold.

DECISION Exam-response coordinator in a mortgage company after a pricing-regression spike must choose The CRA plan is strategy / Window dressing using model-reason-code mapping that does not match notices after a marketing mailer that skipped majority-minority tracts.

HYPOTHESES TO TEST 1. A marketing mailer that skipped majority-minority tracts is noise around an already-controlled Examination and Notices process in a mortgage company after a pricing-regression spike, given model-reason-code mapping that does not match notices. 2. A marketing mailer that skipped majority-minority tracts is the event in model-reason-code mapping that does not match notices that forces The CRA plan is strategy for exam-response coordinator under Fair Lending. 3. Model-reason-code mapping that does not match notices shows a one-file miss after a marketing mailer that skipped majority-minority tracts, not a Examination and Notices program failure. 4. Model-reason-code mapping that does not match notices cannot decide the CRA plan is yet after a marketing mailer that skipped majority-minority tracts; hold is the only Fair Lending close a mortgage company after a pricing-regression spike can defend.

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 marketing mailer that skipped majority-minority tracts. 3. Flag any disparate-impact table exam-response coordinator cannot explain from model-reason-code mapping that does not match notices. 4. For this Fair Lending Examination and Notices file, read model-reason-code mapping that does not match notices against a marketing mailer that skipped majority-minority tracts 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 / Examination and Notices packet (model-reason-code mapping that does not match notices after a marketing mailer that skipped majority-minority tracts). The follow-on Examination and Notices action is what exam-response coordinator does next: implement the option, assign an owner, and log the missing fact.

COMMAND RETURNS - Bottom-line Fair Lending option on the CRA plan is, then the evidence in model-reason-code mapping that does not match notices, then the action for exam-response coordinator - Hypothesis scorecard against model-reason-code mapping that does not match notices: supported / rejected / untestable - What changes the CRA plan is if a marketing mailer that skipped majority-minority tracts is later withdrawn - Named option among The CRA plan is strategy, Window dressing and the fact that kills the others