Assess whether the CRA plan is strategy or window dressing (3e2f15)

SITUATION In an institution preparing for a redlining exam, underwriting exception log by branch is the evidence after a community complaint about appraisal gaps. Community-development lender has to pick The CRA plan is strategy or Window dressing for this Fair Lending CRA and Special-Purpose Programs close using underwriting exception log by branch.

DECISION Community-development lender in an institution preparing for a redlining exam must choose The CRA plan is strategy / Window dressing using underwriting exception log by branch after a community complaint about appraisal gaps.

HYPOTHESES TO TEST 1. Community-development lender can defend The CRA plan is strategy from underwriting exception log by branch after a community complaint about appraisal gaps in a Fair Lending challenge. 2. Community-development lender cannot defend The CRA plan is strategy from underwriting exception log by branch; Window dressing is what the extract actually supports after a community complaint about appraisal gaps. 3. A community complaint about appraisal gaps never reached the population in underwriting exception log by branch — reopen intake, do not close the CRA plan is. 4. Two facts in underwriting exception log by branch after a community complaint about appraisal gaps conflict for community-development lender; hold this CRA and Special-Purpose Programs file.

ANALYSIS REQUIRED 1. Check HMDA coding and underwriting policy against the CRA plan is. 2. Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after a community complaint about appraisal gaps. 3. Flag any disparate-impact table community-development lender cannot explain from underwriting exception log by branch. 4. For this Fair Lending CRA and Special-Purpose Programs file, read underwriting exception log by branch against a community complaint about appraisal gaps 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 (underwriting exception log by branch after a community complaint about appraisal gaps). If underwriting exception log by branch cannot force a Fair Lending label under CRA and Special-Purpose Programs, stop. If underwriting exception log by branch after a community complaint about appraisal gaps cannot support The CRA plan is strategy versus Window dressing on this Fair Lending CRA and Special-Purpose Programs close, community-development lender must do not infer a control or scheme beyond the transaction and entitlement evidence.

COMMAND RETURNS - Bottom-line Fair Lending option on the CRA plan is, then the evidence in underwriting exception log by branch, then the action for community-development lender - Hypothesis scorecard against underwriting exception log by branch: supported / rejected / untestable - Named option among The CRA plan is strategy, Window dressing and the fact that kills the others - Owner and next date for community-development lender in an institution preparing for a redlining exam