Assess whether the CRA plan is strategy or window dressing (101557)

SITUATION After an exception rate twice as high for one group after credit controls, underwriting exception log by branch is what second-review underwriter can touch in a small-business desk using a new vendor score. Fair Lending will live with The CRA plan is strategy versus Window dressing on this Redlining and HMDA Data file.

DECISION Second-review underwriter in a small-business desk using a new vendor score must choose The CRA plan is strategy / Window dressing using underwriting exception log by branch after an exception rate twice as high for one group after credit controls.

HYPOTHESES TO TEST 1. Second-review underwriter can defend The CRA plan is strategy from underwriting exception log by branch after an exception rate twice as high for one group after credit controls in a Fair Lending challenge. 2. Second-review underwriter cannot defend The CRA plan is strategy from underwriting exception log by branch; Window dressing is what the extract actually supports after an exception rate twice as high for one group after credit controls. 3. An exception rate twice as high for one group after credit controls 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 an exception rate twice as high for one group after credit controls conflict for second-review underwriter; hold this Redlining and HMDA Data file.

ANALYSIS REQUIRED 1. Match the adverse-action language to the facts in underwriting exception log by branch. 2. Check HMDA coding and underwriting policy against the CRA plan is. 3. Compare underwriting exception log by branch to similarly situated files, second-review notes, and reason codes after an exception rate twice as high for one group after credit controls. 4. For this Fair Lending Redlining and HMDA Data file, read underwriting exception log by branch against an exception rate twice as high for one group after credit controls and write the one fact that would move the CRA plan is for second-review underwriter.

RECOMMENDATION Choose The CRA plan is strategy / Window dressing on this Fair Lending / Redlining and HMDA Data packet (underwriting exception log by branch after an exception rate twice as high for one group after credit controls). If underwriting exception log by branch cannot force a Fair Lending label under Redlining and HMDA Data, stop. If underwriting exception log by branch after an exception rate twice as high for one group after credit controls cannot support The CRA plan is strategy versus Window dressing on this Fair Lending Redlining and HMDA Data close, second-review underwriter must do not infer a control or scheme beyond the transaction and entitlement evidence.