Assess whether the CRA plan is strategy or window dressing (b921ee)

SITUATION Fair-lending officer owns this CRA and Special-Purpose Programs review in a bank with thin HMDA LAR quality. An underwriter chat that used coded language is the triggering event; underwriting exception log by branch is the evidence for whether the CRA plan is strategy or window dressing.

DECISION Fair-lending officer in a bank with thin HMDA LAR quality must choose The CRA plan is strategy / Window dressing using underwriting exception log by branch after an underwriter chat that used coded language.

HYPOTHESES TO TEST 1. Fair-lending officer can defend The CRA plan is strategy from underwriting exception log by branch after an underwriter chat that used coded language in a Fair Lending challenge. 2. Fair-lending officer cannot defend The CRA plan is strategy from underwriting exception log by branch; Window dressing is what the extract actually supports after an underwriter chat that used coded language. 3. An underwriter chat that used coded language 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 underwriter chat that used coded language conflict for fair-lending officer; hold this CRA and Special-Purpose Programs file.

ANALYSIS REQUIRED 1. Test a documented exception versus a pattern a bank with thin HMDA LAR quality 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 CRA and Special-Purpose Programs file, read underwriting exception log by branch against an underwriter chat that used coded language and write the one fact that would move the CRA plan is for fair-lending officer.

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 an underwriter chat that used coded language). Lead with the Fair Lending option underwriting exception log by branch can support after an underwriter chat that used coded language, then the two facts that force it, then the Monday action for fair-lending officer in a bank with thin HMDA LAR quality.

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 fair-lending officer - Hypothesis scorecard against underwriting exception log by branch: supported / rejected / untestable - Owner and next date for fair-lending officer in a bank with thin HMDA LAR quality - What changes the CRA plan is if an underwriter chat that used coded language is later withdrawn