Assess whether pricing disparities are justified by legitimate factors

SITUATION Adverse-action notice operations lead in a credit-card issuer changing line-assignment logic has one working extract — credit-card limit assignment disparity table — after a board asking if the bank should settle a matched-pair study. If credit-card limit assignment disparity table cannot support pricing disparities are justified, the only defensible Fair Lending output is hold.

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 credit-card limit assignment disparity table after a board asking if the bank should settle a matched-pair study.

HYPOTHESES TO TEST 1. Credit-card limit assignment disparity table reads as Remove access or reverse the item once a board asking if the bank should settle a matched-pair study is lined up to the same Fair Lending population. 2. Credit-card limit assignment disparity table is closer to Temporary compensating control after a board asking if the bank should settle a matched-pair study; Remove access or reverse the item would over-claim this Examination and Notices extract. 3. Approve a documented exception is still live in credit-card limit assignment disparity table for adverse-action notice operations lead in a credit-card issuer changing line-assignment logic. 4. Credit-card limit assignment disparity table is missing the fact adverse-action notice operations lead needs after a board asking if the bank should settle a matched-pair study; stop this Fair Lending close.

ANALYSIS REQUIRED 1. Flag any disparate-impact table adverse-action notice operations lead cannot explain from credit-card limit assignment disparity table. 2. Test a documented exception versus a pattern a credit-card issuer changing line-assignment logic must defend. 3. Match the adverse-action language to the facts in credit-card limit assignment disparity table. 4. For this Fair Lending Examination and Notices file, read credit-card limit assignment disparity table against a board asking if the bank should settle a matched-pair study and write the one fact that would move pricing disparities are justified for adverse-action notice operations lead.

RECOMMENDATION Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Fair Lending / Examination and Notices packet (credit-card limit assignment disparity table after a board asking if the bank should settle a matched-pair study). The follow-on Examination and Notices action is what adverse-action notice operations lead does next: implement the option, assign an owner, and log the missing fact.