Assess whether the CRA plan is strategy or window dressing from SPCP written

SITUATION The working file is SPCP written plan versus actual originations after a DOJ or CFPB monitor request for pricing files. HMDA data-quality manager in a lender expanding into majority-minority census tracts has to name The CRA plan is strategy or Window dressing for this Fair Lending Pricing and Credit Limits file.

DECISION HMDA data-quality manager in a lender expanding into majority-minority census tracts must choose The CRA plan is strategy / Window dressing using SPCP written plan versus actual originations after a DOJ or CFPB monitor request for pricing files.

HYPOTHESES TO TEST 1. SPCP written plan versus actual originations reads as The CRA plan is strategy once a DOJ or CFPB monitor request for pricing files is lined up to the same Fair Lending population. 2. SPCP written plan versus actual originations is closer to Window dressing after a DOJ or CFPB monitor request for pricing files; The CRA plan is strategy would over-claim this Pricing and Credit Limits extract. 3. A dual reading is still live in SPCP written plan versus actual originations for HMDA data-quality manager in a lender expanding into majority-minority census tracts. 4. SPCP written plan versus actual originations is missing the fact HMDA data-quality manager needs after a DOJ or CFPB monitor request for pricing files; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the CRA plan is. 2. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a DOJ or CFPB monitor request for pricing files. 3. Flag any disparate-impact table HMDA data-quality manager cannot explain from SPCP written plan versus actual originations. 4. For this Fair Lending Pricing and Credit Limits file, read SPCP written plan versus actual originations against a DOJ or CFPB monitor request for pricing files 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 (SPCP written plan versus actual originations after a DOJ or CFPB monitor request for pricing files). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a DOJ or CFPB monitor request for pricing files, 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.

COMMAND RETURNS - Bottom-line Fair Lending option on the CRA plan is, then the evidence in SPCP written plan versus actual originations, then the action for HMDA data-quality manager - Hypothesis scorecard against SPCP written plan versus actual originations: supported / rejected / untestable - Missing page in SPCP written plan versus actual originations after a DOJ or CFPB monitor request for pricing files, if any - Regulatory or exam hook Pricing and Credit Limits would cite