Assess whether the CRA plan is strategy or window dressing (17fe39)

SITUATION Fair-lending officer in a manufactured-housing lender with dealer-originated files has one working extract — small-business decline comparative file set — after a branch that stopped taking applications in one ZIP. If small-business decline comparative file set cannot support the CRA plan is, the only defensible Fair Lending output is hold.

DECISION Fair-lending officer in a manufactured-housing lender with dealer-originated files must choose The CRA plan is strategy / Window dressing using small-business decline comparative file set after a branch that stopped taking applications in one ZIP.

HYPOTHESES TO TEST 1. Authorize The CRA plan is strategy now; small-business decline comparative file set already has the discriminator after a branch that stopped taking applications in one ZIP. 2. Keep Window dressing in force until small-business decline comparative file set is completed after a branch that stopped taking applications in one ZIP for fair-lending officer. 3. Treat small-business decline comparative file set as The CRA plan is strategy because both readings appear after a branch that stopped taking applications in one ZIP. 4. Refuse a Fair Lending close: fair-lending officer does not have the decision the CRA plan is turns on in small-business decline comparative file set.

ANALYSIS REQUIRED 1. Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a branch that stopped taking applications in one ZIP. 2. Flag any disparate-impact table fair-lending officer cannot explain from small-business decline comparative file set. 3. Test a documented exception versus a pattern a manufactured-housing lender with dealer-originated files must defend. 4. For this Fair Lending Redlining and HMDA Data file, read small-business decline comparative file set against a branch that stopped taking applications in one ZIP 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 / Redlining and HMDA Data packet (small-business decline comparative file set after a branch that stopped taking applications in one ZIP). Lead with the Fair Lending option small-business decline comparative file set can support after a branch that stopped taking applications in one ZIP, then the two facts that force it, then the Monday action for fair-lending officer in a manufactured-housing lender with dealer-originated files.

COMMAND RETURNS - Bottom-line Fair Lending option on the CRA plan is, then the evidence in small-business decline comparative file set, then the action for fair-lending officer - Hypothesis scorecard against small-business decline comparative file set: supported / rejected / untestable - Owner and next date for fair-lending officer in a manufactured-housing lender with dealer-originated files - What changes the CRA plan is if a branch that stopped taking applications in one ZIP is later withdrawn