Assess whether the CRA plan is strategy or window dressing (559384)

SITUATION In a mortgage company after a pricing-regression spike, underwriting exception log by branch is the evidence after a SPCP that originated almost no loans to the intended class. Exam-response coordinator has to pick The CRA plan is strategy or Window dressing for this Fair Lending Examination and Notices close using underwriting exception log by branch.

DECISION Exam-response coordinator in a mortgage company after a pricing-regression spike must choose The CRA plan is strategy / Window dressing using underwriting exception log by branch after a SPCP that originated almost no loans to the intended class.

HYPOTHESES TO TEST 1. Exam-response coordinator can defend The CRA plan is strategy from underwriting exception log by branch after a SPCP that originated almost no loans to the intended class in a Fair Lending challenge. 2. Exam-response coordinator cannot defend The CRA plan is strategy from underwriting exception log by branch; Window dressing is what the extract actually supports after a SPCP that originated almost no loans to the intended class. 3. A SPCP that originated almost no loans to the intended class 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 SPCP that originated almost no loans to the intended class conflict for exam-response coordinator; hold this Examination and Notices file.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a mortgage company after a pricing-regression spike must defend. 2. Match the adverse-action language to the facts in underwriting exception log by branch. 3. Check HMDA coding and underwriting policy against the CRA plan is. 4. For this Fair Lending Examination and Notices file, read underwriting exception log by branch against a SPCP that originated almost no loans to the intended class 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 (underwriting exception log by branch after a SPCP that originated almost no loans to the intended class). If underwriting exception log by branch cannot force a Fair Lending label under Examination and Notices, stop. If underwriting exception log by branch after a SPCP that originated almost no loans to the intended class cannot support The CRA plan is strategy versus Window dressing on this Fair Lending Examination and Notices close, exam-response coordinator 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 exam-response coordinator - 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 exam-response coordinator in a mortgage company after a pricing-regression spike