Assess whether the CRA plan is strategy or window dressing (269975)

SITUATION SPCP written plan versus actual originations arrived with a notice that cites 'other' as the principal reason 40% of the time for exam-response coordinator. That is a Fair Lending Examination and Notices decision on the CRA plan is in a mortgage company after a pricing-regression spike.

DECISION Exam-response coordinator in a mortgage company after a pricing-regression spike must choose The CRA plan is strategy / Window dressing using SPCP written plan versus actual originations after a notice that cites 'other' as the principal reason 40% of the time.

HYPOTHESES TO TEST 1. A notice that cites 'other' as the principal reason 40% of the time is noise around an already-controlled Examination and Notices process in a mortgage company after a pricing-regression spike, given SPCP written plan versus actual originations. 2. A notice that cites 'other' as the principal reason 40% of the time is the event in SPCP written plan versus actual originations that forces The CRA plan is strategy for exam-response coordinator under Fair Lending. 3. SPCP written plan versus actual originations shows a one-file miss after a notice that cites 'other' as the principal reason 40% of the time, not a Examination and Notices program failure. 4. SPCP written plan versus actual originations cannot decide the CRA plan is yet after a notice that cites 'other' as the principal reason 40% of the time; hold is the only Fair Lending close a mortgage company after a pricing-regression spike can defend.

ANALYSIS REQUIRED 1. Compare SPCP written plan versus actual originations to similarly situated files, second-review notes, and reason codes after a notice that cites 'other' as the principal reason 40% of the time. 2. Flag any disparate-impact table exam-response coordinator cannot explain from SPCP written plan versus actual originations. 3. Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend. 4. For this Fair Lending Examination and Notices file, read SPCP written plan versus actual originations against a notice that cites 'other' as the principal reason 40% of the time 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 (SPCP written plan versus actual originations after a notice that cites 'other' as the principal reason 40% of the time). Lead with the Fair Lending option SPCP written plan versus actual originations can support after a notice that cites 'other' as the principal reason 40% of the time, then the two facts that force it, then the Monday action for exam-response coordinator in a mortgage company after a pricing-regression spike.