Assess whether line assignments have a disparate impact the bank will defend

Situation

After a marketing mailer that skipped majority-minority tracts, geographic application and origination heat map is what adverse-action notice operations lead can touch in a credit-card issuer changing line-assignment logic. Fair Lending will live with Remove access or reverse the item versus Temporary compensating control on this Examination and Notices file.

Decision

Adverse-action notice operations lead in a credit-card issuer changing line-assignment logic must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using geographic application and origination heat map after a marketing mailer that skipped majority-minority tracts.

Hypotheses to test

• Geographic application and origination heat map reads as Remove access or reverse the item once a marketing mailer that skipped majority-minority tracts is lined up to the same Fair Lending population.
• Geographic application and origination heat map is closer to Temporary compensating control after a marketing mailer that skipped majority-minority tracts; Remove access or reverse the item would over-claim this Examination and Notices extract.
• Approve a documented exception is still live in geographic application and origination heat map for adverse-action notice operations lead in a credit-card issuer changing line-assignment logic.
• Geographic application and origination heat map is missing the fact adverse-action notice operations lead needs after a marketing mailer that skipped majority-minority tracts; stop this Fair Lending close.

Analysis required

• Match the adverse-action language to the facts in geographic application and origination heat map.
• Check HMDA coding and underwriting policy against line assignments have a.
• Compare geographic application and origination heat map to similarly situated files, second-review notes, and reason codes after a marketing mailer that skipped majority-minority tracts.
• For this Fair Lending Examination and Notices file, read geographic application and origination heat map against a marketing mailer that skipped majority-minority tracts and write the one fact that would move line assignments have a for adverse-action notice operations lead.

Recommendation