Assess whether the CRA plan is strategy or window dressing (cba753)

SITUATION Small-business decline comparative file set arrived with a CRA PE that called the assessment area too narrow for community-development lender. That is a Fair Lending CRA and Special-Purpose Programs decision on the CRA plan is in an institution preparing for a redlining exam.

DECISION Community-development lender in an institution preparing for a redlining exam must choose The CRA plan is strategy / Window dressing using small-business decline comparative file set after a CRA PE that called the assessment area too narrow.

HYPOTHESES TO TEST 1. The population in small-business decline comparative file set is the one a CRA PE that called the assessment area too narrow named, so The CRA plan is strategy follows for this CRA and Special-Purpose Programs file. 2. The population in small-business decline comparative file set is adjacent only to a CRA PE that called the assessment area too narrow; Window dressing is the honest Fair Lending call. 3. An institution preparing for a redlining exam already contained a CRA PE that called the assessment area too narrow before small-business decline comparative file set arrived; no new CRA and Special-Purpose Programs path. 4. Provenance on small-business decline comparative file set after a CRA PE that called the assessment area too narrow is broken; do not pick The CRA plan is strategy or Window dressing yet.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in small-business decline comparative file set. 2. Check HMDA coding and underwriting policy against the CRA plan is. 3. Compare small-business decline comparative file set to similarly situated files, second-review notes, and reason codes after a CRA PE that called the assessment area too narrow. 4. For this Fair Lending CRA and Special-Purpose Programs file, read small-business decline comparative file set against a CRA PE that called the assessment area too narrow and write the one fact that would move the CRA plan is for community-development lender.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / CRA and Special-Purpose Programs packet (small-business decline comparative file set after a CRA PE that called the assessment area too narrow). The follow-on CRA and Special-Purpose Programs action is what community-development lender 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 small-business decline comparative file set, then the action for community-development lender - Hypothesis scorecard against small-business decline comparative file set: supported / rejected / untestable - Missing page in small-business decline comparative file set after a CRA PE that called the assessment area too narrow, if any - Regulatory or exam hook CRA and Special-Purpose Programs would cite